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No Surprises Act · California

Out-of-network claims in California — that payment is an opening offer

Dispute pathway: Federal IDR + state pathway

Out-of-network surgical and hospital-based claims in California are routinely paid below the billed charge or denied outright. Under the No Surprises Act that payment is an opening offer, and dispute resolution exists to contest it. Sydra checks what qualifies, assembles the submission, holds every deadline, and can file it for you.

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How disputes route in California

Federal IDR + state pathway

California's AB 72 (2016; Health & Safety Code §1371.9) protects patients from surprise bills for non-emergency care by noncontracting individual professionals at contracting facilities. For DMHC-regulated plans, a provider who disputes the payment first completes the plan's Provider Dispute Resolution process and can then apply to DMHC's Independent Dispute Resolution Process (IDRP), where an independent reviewer sets the reimbursement. Emergency services and self-funded ERISA plans are outside this process.

Claims under DMHC-regulated plans can go to California's AB 72 IDRP, and insurers regulated by the Department of Insurance (CDI) have a separate track. Self-funded ERISA plans follow the federal IDR process. Confirm the plan's regulator before filing.

What's specific to California

  • The DMHC process is not baseball-style: the reviewer is not bound to either side's number and sets its own reimbursement, itemized by billing code.
  • It covers non-emergency services by a noncontracting individual health professional at, or as a result of services at, a contracting facility, and the plan's own Provider Dispute Resolution process must be completed first.
  • CDI-regulated health insurers run their own AB 72 process (Insurance Code §10112.81), so the plan's regulator decides which California forum applies.

Deadlines once a California dispute is running

  1. Payor acknowledges or issues the PDR determination

    45 business days

    from the payor receiving the dispute

    If nothing comes back, dated proof of the attempt substitutes once this period matures. Completing the plan's Provider Dispute Resolution process is a hard gate before the IDRP.

    DMHC IDRP eligibility criteria

  2. Independent organization issues its binding written determination

    30 calendar days

    from review beginning

    Binding on both parties. DMHC's written procedures, which fix exactly when this clock starts, have not yet been verified.

    Health & Safety Code §1371.9

These are the steps once a dispute is already running. The window to file in the first place turns on the plan type and on which date the clock runs from, so we check it against the claim in front of us rather than a general figure.

Claims that go to federal IDR follow a defined pathway between a payer's underpayment and a binding payment determination — an open negotiation window, an eligibility determination, a batching decision, then a decision by a certified IDR entity. Claims under California's own law follow the state rules described above instead. Each step has its own deadline, and missing one can cost the claim. Providers win roughly 88% of federal IDR determinations they contest. Sydra is a capped, predictable fee — less than half of what most contingency firms charge. We file it, you keep the recovery.

Browse by specialty

Commonly disputed procedures in California

Anterior cervical discectomy and fusion, single level (CPT 22551)Anterior cervical fusion, each additional level (CPT 22552)Cervical or thoracic epidural injection with imaging (CPT 62321)Lumbar or sacral epidural injection with imaging (CPT 62323)Total hip replacement (CPT 27130)Partial hip replacement (hemiarthroplasty) (CPT 27125)Craniotomy for brain tumor removal, supratentorial (CPT 61510)Craniotomy for meningioma removal, supratentorial (CPT 61512)Muscle flap, trunk (CPT 15734)Muscle flap, lower extremity (CPT 15738)Wrist joint replacement (interposition arthroplasty) (CPT 25447)Flexor tendon repair in zone 2, single (CPT 26356)Emergency department visit, minor (CPT 99281)Emergency department visit, low complexity (CPT 99282)CT scan of the head, without contrast (CPT 70450)CT scan of the head, with contrast (CPT 70460)Tissue exam under the microscope, level IV (CPT 88305)Tissue exam under the microscope, level III (CPT 88304)Epidural anesthesia for labor and delivery (CPT 01967)Anesthesia for upper abdominal surgery (CPT 00790)Correction, hammertoe (CPT 28285)Capsulotomy; midfoot (CPT 28270)Initial neonatal critical care, 28 days or younger (CPT 99468)Subsequent neonatal critical care, 28 days or younger (CPT 99469)Cataract removal with intraocular lens (CPT 66984)Intravitreal injection of a pharmacologic agent (CPT 67028)Initial hospital inpatient care, high complexity (CPT 99223)Subsequent hospital inpatient care, high complexity (CPT 99233)Central venous catheter insertion, age 5 or older (CPT 36556)Arterial catheterization for monitoring (CPT 36620)Coronary artery bypass, single arterial graft (CPT 33533)Laparoscopic cholecystectomy (CPT 47562)Incision and drainage of abscess, simple (CPT 10060)Debridement, subcutaneous tissue (CPT 11042)

Return to the Federal IDR hub.

No outcome is guaranteed. Results vary by claim, payer, specialty, and documentation. State routing depends on plan type; confirm against the CMS applicability chart before filing. This is general information, not legal or financial advice.

JA

Medically & clinically reviewed by Dr. John M. Abrahams, MD

Board-certified neurosurgeon and founder of Sydra · Last reviewed September 2026 · About the author

Figures reflect the published federal record across all disputes, not a prediction about any individual claim. This is general information, not legal or financial advice.