Bifurcated

Virginia No Surprises Act & IDR Rules

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

Quick answer: Virginia is a bifurcated state. Some disputes are governed by Virginia's own specified state law, while others default to the federal No Surprises Act IDR process depending on the plan type and service involved.

How it works

Virginia's specified state law applies to emergency services at in-network or out-of-network hospitals (excluding post-stabilization at out-of-network hospitals) and non-emergency surgical or ancillary services at in-network facilities, for Virginia-issued fully-insured plans and opted-in self-funded plans. The federal IDR process applies to independent freestanding emergency facilities, post-stabilization services, and most other non-emergency claims, plus air ambulance services. Virginia is also one of six states that allows self-funded ERISA plans to voluntarily opt into the state process.

Key dates

Federal No Surprises Act protections took effect January 1, 2022. State-specific protections vary — check the official source below for exact effective dates in this state.

Official source: Centers for Medicare & Medicaid Services — Virginia enforcement letter and specified state law documentation (cms.gov/nosurprises)

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