The Eastern District of Texas is The Fourth Federal Court in Six Weeks to Reject Insurer Attempts to Relitigate IDR Awards Under the No Surprises Act
DALLAS, May 27, 2026 /PRNewswire/ — HaloMD today secured a decisive victory in the U.S. District Court for the Eastern District of Texas after Judge Robert W. Schroeder III dismissed with prejudice all seven claims brought by Blue Cross Blue Shield of Texas (BCBS Texas), a division of Chicago-based Health Care Service Corporation (HCSC), against HaloMD and the other defendants.
In an 18-page ruling, the Court rejected BCBS Texas’s attempt to use a combination of federal and state law theories to undermine the No Surprises Act (NSA) and the binding nature of awards issued under Independent Dispute Resolution (IDR). In response to BCBS Texas’s attempted end-run around the arbitration process, the Court found that, “…the collateral attack doctrine is even more clearly applicable where, as here, Plaintiff is attempting to relitigate issues previously decided by the IDR entities…”. The same analysis applied to claims arising under the Texas IDR process established by Senate Bill 1264.
“The court got this case exactly right,” said Justin Carangelo, General Counsel and Chief Compliance Officer of HaloMD. “The NSA forecloses judicial review of IDR awards. This is the fourth federal court to reject attempts to weaken the NSA in the last six weeks. Insurers engaged in similarly wasteful litigation should assess whether continuing to do so is an intelligent use of resources.”
“Left unresolved by today’s decision, in HaloMD’s view, is the growing backlog of past-due payments under the No Surprises Act that BCBS Texas and parent company HCSC owe to healthcare providers for care already provided to patients,” said Patrick Velliky, Chief External Affairs Officer of HaloMD. “HaloMD maintains HCSC has failed to pay tens-of-millions-of-dollars in legally binding awards.”
A Pattern of Rulings Defending the IDR Framework
Today’s dismissal follows similar rulings in litigation against HaloMD, as well as other unrelated parties, across federal courts, including the dismissal of an almost identical suit in the Central District of California, a parallel ruling in the Middle District of Florida, and an additional dismissal in the Eastern District of Pennsylvania.
Since taking effect on January 1, 2022, the No Surprises Act has protected millions of Americans from surprise medical bills. The law established the IDR process as the binding mechanism for resolving payment disputes between out-of-network providers and insurers, while holding patients harmless from financial exposure beyond their in-network responsibility. Texas Senate Bill 1264, enacted in 2019, established a state IDR process with its own limits on judicial review. In both frameworks, IDR determinations, once made, are final and binding by design.
The case is Blue Cross Blue Shield of Texas v. HaloMD, LLC et al., Case No. 5:25-CV-132-RWS (E.D. Tex.).
About HaloMD
HaloMD is the #1 provider of Independent Dispute Resolution (IDR) services as indicated by public CMS data, backed by industry leading technology infrastructure and data intelligence. The company supports healthcare providers navigating the federal No Surprises Act and state balance-billing laws, combining proprietary technology, advanced analytics, and deep specialty expertise to advance fair reimbursement, long-term financial sustainability, and empowering care teams to focus on providing high quality patient care.
Privately held and founder-led, HaloMD serves more than 20,000 providers, from independent physicians to hospitals and health systems, across 50 states and Washington, D.C., so they can continue caring for the patients and communities they serve.
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SOURCE HaloMD
