Source: STAT
The No Surprises Act created a lucrative arbitration system to resolve surprise medical bills, but nonprofits like iMPROve Health have turned the role into a self-enriching enterprise with minimal oversight. These arbitrators operate with near-total discretion over billing disputes affecting millions of patients, yet face almost no accountability mechanisms or transparency requirements from CMS. The structure shows how regulation can be hollowed out when intermediaries capture the enforcement mechanism itself—converting government-mandated fairness into a revenue stream for players with no stake in actual healthcare outcomes.