What is TDI Chapter 1467 and how does it help out-of-network providers?

Texas Insurance Code Chapter 1467 is a state law that gives out-of-network healthcare providers a formal pathway to dispute inadequate reimbursement from fully-insured commercial health plans regulated by the Texas Department of Insurance. When an insurer underpays or denies a claim without clinical justification, Chapter 1467 allows providers to initiate binding arbitration before an independent arbitrator. A well-constructed case typically recovers significantly more than the insurer's original payment.

What is the No Surprises Act and who does it apply to?

The federal No Surprises Act (NSA) established an Independent Dispute Resolution (IDR) process for out-of-network claims involving self-insured ERISA plans — typically large employer health plans. Unlike TDI Chapter 1467 which covers state-regulated fully-insured plans, the NSA covers federal ERISA plans. The NSA uses a baseball-style arbitration where the arbitrator selects one party's offer in full, making submission quality critical.

Does MEG Law charge upfront fees for out-of-network billing disputes?

No. MEG Law works on a contingency fee basis — there are no upfront fees, no filing costs out of pocket, and no hourly billing. MEG Law earns a percentage of what it recovers on the client's behalf. If nothing is recovered, the client owes nothing.

What types of healthcare providers does MEG Law represent?

MEG Law represents out-of-network surgical providers across Texas including surgeons and surgical groups, ambulatory surgical centers, anesthesiology providers, certified surgical technologists and first assistants, imaging and diagnostic centers, pain management and spine specialists, and other specialty providers with underpaid or denied claims.

What is the difference between TDI IDR and NSA arbitration?

TDI Chapter 1467 covers fully-insured health plans regulated by the Texas Department of Insurance. The NSA covers self-insured ERISA plans, which are typically large employer plans. The two frameworks have different rules, timelines, arbitrator standards, and submission requirements. Many providers have claims under both frameworks. MEG Law handles both and identifies which applies to each claim.

How long does the TDI or NSA arbitration process take?

TDI Chapter 1467 disputes typically resolve within several months from initiation to arbitration award. NSA IDR timelines are governed by federal regulation and generally take 30 to 90 days from submission depending on the complexity and whether extensions are granted. MEG Law provides timeline estimates during the initial consultation based on the specific claim.

Practice Areas | MEG Law — TDI Chapter 1467 & No Surprises Act Attorneys, Dallas TX

Texas Insurance Code

TDI Independent Dispute Resolution — Chapter 1467

Texas Insurance Code Chapter 1467 gives out-of-network providers a powerful, state-enforced pathway to dispute inadequate reimbursement by fully-insured commercial health plans regulated by the Texas Department of Insurance.

When a payer underpays or improperly denies an out-of-network claim (without clinical justification), Chapter 1467 opens the door to arbitration before an independent arbitrator who is bound by strict standards. A well-constructed case typically recovers significantly more than the insurer's original payment.

MEG Law manages the entire IDR process on your behalf: eligibility assessment, dispute initiation, documentation preparation, legal brief development, and arbitration hearing representation.

→ Applies to fully-insured plans regulated by the Texas Department of Insurance
→ Covers emergency and non-emergency out-of-network services
→ Arbitrators must consider billed charges, usual and customary rates, and clinical complexity
→ Strict timelines and procedural requirements. Getting it right matters.
→ We handle disputes from individual claims to high-volume portfolios

Discuss a TDI Dispute

What We Handle Under Chapter 1467

Emergency surgical services: underpaid by commercial plan

Non-emergency out-of-network surgical claims denied without clinical basis

Anesthesiology services at in-network facility paid at out-of-network rates

Certified Surgical Technologist and First Assistant claims

Specialty services reimbursed far below usual and customary rates

Imaging and diagnostic services denied by TDI-regulated plans

Not sure if Chapter 1467 applies? The framework only covers fully-insured plans regulated by TDI, not self-insured ERISA plans. We'll assess your claim's coverage on the first call.

Federal Law

No Surprises Act: Federal Independent Dispute Resolution

The federal No Surprises Act established an Independent Dispute Resolution process for out-of-network claims involving self-insured ERISA plans (the large employer plans that TDI cannot regulate. For many providers, the NSA IDR process is the only avenue available for those claims.

The NSA IDR requires providers to submit offers that certified arbitrators evaluate against the Qualifying Payment Amount (QPA) and other statutory factors. The difference between a strong submission and a weak one directly determines what you recover.

MEG Law handles NSA disputes with the same focus and rigor we bring to TDI matters, building submissions that give our clients the strongest possible outcome at arbitration.

→ Applies to self-insured ERISA plans (most large employer health plans)
→ Covers non-emergency out-of-network services at in-network facilities
→ "Baseball-style" arbitration: the arbitrator selects one offer in full
→ Offer framing and documentation are critical. Submission quality wins cases.
→ Distinct rules, timelines, and strategy from TDI Chapter 1467

Discuss a NSA Dispute

What We Handle Under the NSA

Out-of-network surgical care at in-network hospitals or ASCs

Anesthesiology services where the patient had no in-network option

Emergency services, including air ambulance and ground transport

Non-emergency services where prior authorization was obtained

Claims where QPA is being used to systematically underpay providers

Portfolio-based NSA submissions for high-volume providers

NSA vs. TDI: Many providers have claims that fall under both frameworks. We identify which mechanism applies and build the right strategy for each.

Reimbursement Recovery

Insurance Underpayment Disputes

Underpayment is the most common form of insurer misconduct in the out-of-network space. A payer processes the claim, sends a payment, and the amount falls dramatically short of what the service warranted. No denial, no explanation. Just a short check.

Providers often lack the time or legal resources to challenge individual underpayments. MEG Law steps in to aggregate, evaluate, and pursue those claims at no upfront cost, using the IDR mechanisms that exist precisely for this purpose.

→ Systematic underpayment patterns across a provider's book of claims
→ Single large-value underpaid claims requiring immediate dispute
→ Payer fee schedule manipulation: payments set below market rates without justification
→ Bundling or downcoding of complex surgical procedures

Evaluate Your Underpayments

Common Underpayment Tactics We Counter

QPA manipulation: setting qualifying payment amounts artificially low

Procedure bundling: refusing to reimburse separately billable CPT codes

Assistant surgeon denial: rejecting medically necessary assistance claims

Fee schedule application: reimbursing at rates far below usual and customary

Clinical complexity downcoding: misclassifying high-complexity procedures

Claims Recovery

Denied Out-of-Network Claims

Outright denial: the insurer refuses to pay the claim at all. Often the denial is issued with a boilerplate justification: "not medically necessary," "not covered," or "out-of-network." These denials are frequently wrong, and many can be successfully challenged through IDR.

MEG Law analyzes denied claims to determine whether the denial is clinically defensible or whether the insurer is using denial as a leverage tactic. Where arbitration is available, we build the case and pursue it.

→ "Not medically necessary" denials lacking clinical support
→ Emergency claims denied for failure to obtain prior authorization
→ Claims denied as "out-of-network" where network adequacy is a factor
→ Coverage denials that contradict the terms of the applicable plan

Discuss a Denied Claim

Why Denial Doesn't Mean the End

Denial triggers IDR eligibility. The dispute begins, not ends.

Clinical review often reveals insurer's denial lacks medical basis

Arbitrators are not bound by the insurer's original determination

Emergency service denials face a high bar; insurers must justify them

Pattern denials across a portfolio create leverage in arbitration

TDI Chapter 1467

No Surprises Act (Federal)

Covers: Fully-insured plans regulated by TDI

Covers: Self-insured ERISA plans (large employers)

Arbitration Type: Independent arbitration under TDI rules

Arbitration Type: Baseball-style (arbitrator selects one offer)

Key Standard: Billed charges, usual & customary, complexity

Key Standard: Qualifying Payment Amount (QPA) + additional factors

Jurisdiction: Texas state law

Jurisdiction: Federal law (CMS-administered)

Don't know which applies to your claim? We'll tell you on the first call.

Practice Areas