UHS · 10-Q · 2026Q3 · Full report

Surprise Billing Regulation

UNIVERSAL HEALTH SERVICES INC · 2026-11-06 · Importance 35 · Surprise 42

The No Surprises Act’s federal independent dispute resolution (IDR) process has faced provider-initiated litigation, with courts vacating portions of CMS rules and guidance and prompting pauses and resumptions that delayed claims processing. On June 4, 2026, HHS, the Department of Labor, the Department of the Treasury, and OPM issued a final rule intended to improve the federal IDR process. UHS says it cannot predict the rule’s operational impact.

Key facts

• UHS cannot predict the impact of the federal surprise-billing final rule issued June 4, 2026 on its operations. source
• Rules implementing the Consolidated Appropriations Act of 2021 limited UNIVERSAL HEALTH SERVICES INC hospital-based physicians’ ability to receive higher out-of-network payments, causing the company to increase physician subsidies or replace services at higher cost. source