Indiana (Indiana) has consumer protection rules governing medical billing and insurance practices, but it does not have a state surprise billing law that replaces or supersedes the federal No Surprises Act (NSA).

Beginning January 1, 2022, the federal NSA became the controlling law for out-of-network (OON) payment disputes for nearly all commercial plans in Indiana.

Indiana does not maintain an APCD benchmark, a UCR formula, or a state-run arbitration process.

Indiana relies heavily on the federal NSA to regulate OON payments for emergency and unintentional out-of-network encounters.

Under Indiana + NSA requirements:

• Patients may only be billed their in-network cost-sharing for covered emergency OON services or OON services delivered at an in-network facility.
• OON providers must submit claims directly to the health carrier.
• Carriers must make an initial payment reflecting the plan’s recognized amount, which is the Qualified Payment Amount (QPA) under federal law.
• Patients cannot be balance billed unless they knowingly consent to OON services in situations where consent is permitted.

Indiana does not layer additional payment calculation rules on top of the federal framework.

Indiana does not maintain a state-level arbitration or dispute resolution program for surprise billing matters.

• Indiana does not have a CMS-recognized Specified State Law (SSL).
• Therefore, all eligible reimbursement disputes must be resolved through Federal NSA IDR.
• This includes disputes involving emergency care, facility-based OON care, and air ambulance services.

There is no alternate Indiana arbitration system.

Indiana follows the federal NSA negotiation process, which requires:

• A health plan to issue an initial payment or denial.
• A 30-day open negotiation period between the provider and the insurer.
• If unresolved, escalation into Federal IDR.

Indiana law does not add any additional steps or deadlines beyond the NSA.

Because Indiana uses the federal system, IDR entities must consider federal statutory factors, such as:

• QPA (primary benchmark)
• Provider training, experience, and patient acuity
• Market share of provider or insurer
• Prior contracted rates (within four years)
• Good-faith contracting behavior
• Case complexity or facility characteristics

Indiana does not impose any supplementary arbitration criteria.

Indiana’s balance billing protections are supported by:

• Indiana Department of Insurance (IDOI) consumer protection frameworks
• General state prohibitions on unfair billing practices
• Federal NSA regulations under 45 CFR 149.510 & 149.520

Indiana does not establish a separate state-defined OON payment methodology or arbitration structure.

CMS has confirmed that Indiana does not maintain a Specified State Law (SSL) for determining OON rates.

• Fully insured commercial plans
• Individual market plans
• Small and large group plans
• Self-funded ERISA plans (unless they adopt another SSL — extremely rare)

• The QPA governs OON payment determinations.
• All eligible disputes proceed through Federal IDR.
• Indiana insurers must follow NSA timelines, notices, and dispute resolution procedures.
• Indiana’s regulations protect consumers but do not modify reimbursement pathways.