CMS Guidance

CMS explains required No Surprises Act remark codes for 2027

Source: CMS · July 17, 2026

Summary published October 9, 2026

CMS guidance dated July 17, 2026 explains how health plans and issuers must communicate No Surprises Act payment circumstances through remittance advice remark codes (RARCs).

When do the requirements apply?

The code descriptions take effect November 1, 2026. Required use applies to items and services furnished on or after January 1, 2027—not simply remittances received after that date.

Which codes should revenue cycle teams recognize?

N877 identifies an initial payment under the federal pathway; N876 identifies a covered service with no plan payment under that pathway. Federal IDR may follow unsuccessful open negotiation if all eligibility conditions are met. Other codes distinguish state-law payments, All-Payer Model Agreements, negotiated payments, IDR-determined payments, and services outside NSA protections.

Does a payer’s code decide IDR eligibility?

No. Certified IDR entities ultimately decide eligibility. Providers may disagree with a payer’s coding and initiate IDR after open negotiation, subject to applicable requirements.

Where must the codes appear?

For applicable electronic 835 remittances, the required RARC belongs in the LQ segment of Loop 2110 for each service line. Paper remittances must associate the code with each line within the remittance itself.

Practical takeaway

Review service-line code capture and eligibility workflows before implementation. Codes support review; they do not guarantee eligibility or payment.