Special case

Alaska No Surprises Act & IDR Rules

Last verified: July 2026 · For informational purposes only, not legal advice

Quick answer: Alaska is a special case. Alaska is not listed among the 21 standard bifurcated states or the 28 federal-default states in CMS's official chart — the state asserts that its own balance billing law (AS 21.36.500 / 3 AAC 26.110) applies broadly, including to air ambulance claims, which puts it in some tension with federal guidance.

How it works

Alaska's Division of Insurance has taken the position that its state law applies to out-of-network health care claims paid by insurance companies, including air ambulance providers — an unusual stance since most states can't regulate air ambulance billing due to federal preemption (the Airline Deregulation Act). Because of this unresolved overlap, Alaska disputes deserve extra care to confirm which process actually applies to a specific claim.

Key dates

Federal No Surprises Act protections took effect January 1, 2022. Alaska's state law predates this and continues to be asserted by state regulators.

Official source: Alaska Division of Insurance enforcement letter (via cms.gov/nosurprises)

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