The Definitive Resource • Updated January 2026

The No Surprises Act IDR Guide

A comprehensive analysis of the Independent Dispute Resolution process, featuring data from Brookings, Georgetown, and USC research, plus insights from the industry's leading policy experts.

3.3M

Disputes Filed

85%

Provider Win Rate

$5B

System Costs

192×

Cumulative / annual estimate

Introduction

Understanding the law that changed healthcare payments

Historical research guide: the original narrative was compiled in January 2026 and includes earlier studies and litigation summaries. It is not a current deadline or legal-status reference. For current source-linked process answers, see IDR eligibility, documents, and fees. Statistical source dates describe the underlying research, not a new review of the entire guide.

What is the No Surprises Act?

The No Surprises Act (NSA) is landmark federal legislation that took effect on January 1, 2022. It was designed to protect patients from unexpected medical bills, commonly known as "surprise bills," that occur when patients unknowingly receive care from out-of-network providers.

Before the NSA, patients could receive massive bills for emergency services or when treated by out-of-network providers at in-network facilities. The NSA shifted this burden away from patients and created a system for providers and payers to resolve payment disputes directly.

IDR was supposed to serve as a backstop but it was being used in some states as mechanisms for certain provider types to stay out of network and go to IDR to get the payment levels they would like.

KK
Katie Keith

Director, Center for Health Policy and Law, Georgetown O'Neill Institute

What is Independent Dispute Resolution?

Independent Dispute Resolution (IDR) is the arbitration process established by the No Surprises Act to resolve payment disputes between healthcare providers and insurance companies for out-of-network services.

EXPLORE THE MECHANISM

Two offers. One selection.

Adjust the example offers, then choose a hypothetical outcome. This illustrates final-offer selection—not how an arbitrator weighs evidence.

CHOOSE AN EXAMPLE OUTCOMEOne offer, not an average

The controls do not predict a decision or recommend an offer.

Why IDR Matters for Healthcare

The Congressional Budget Office (CBO) originally projected that the NSA would have a modest dampening effect on health costs and premiums, estimating premium decreases of 0.5% to 1%. The reality has been dramatically different.

There is a realistic possibility that the NSA will raise in-network prices and premiums, the opposite of what CBO predicted at enactment.

LA
Loren Adler

Fellow, USC-Brookings Schaeffer Initiative, Brookings Institution

State of IDR: January 2026

Four years into implementation, the IDR system has evolved into something few predicted. Here's where we stand:

What's Working

  • • Patients protected from surprise bills
  • • 85% of disputes resolved
  • • Provider win rate consistently high
  • • Backlog decreasing (down to ~500K)

What's Concerning

  • • Dispute volume far above annual projections
  • • $5B in system costs (2022 to 2024)
  • • PE firms dominating outcomes
  • • Enforcement uncertainty after court split

IDR By The Numbers

The data that defines the dispute landscape

Volume Statistics

3,324,051

disputes filed from mid-2022 through May 2025

When CMS released regulations for the No Surprises Act, they projected approximately 17,333 disputes annually. The reality has been staggering.

IDR Volume: Projection vs. Reality

Original CMS annual estimate17,333 disputes
Actual filed (mid-2022 to May 2025)3,324,051 disputes
Cumulative total ÷ annual estimate192×
First 9 months alone~190,000 (10× annual projection)

Source: Georgetown CHIR analysis, May 2025. The 192× ratio compares a multi-year total with a one-year estimate; it is not an annual increase.

The volume of IDR disputes continues to surpass agency estimates by millions.

JH
Jack Hoadley

Research Professor Emeritus, Georgetown University

The $5 Billion Problem

$5B

total IDR system costs from 2022 to 2024

Georgetown CHIR's landmark analysis revealed the true cost of the IDR system. These costs are ultimately passed on to consumers through higher premiums and cost-sharing.

2022–2024 · COST COMPOSITION

What makes up the roughly $5B total?

Select a category to inspect its contribution. Percentages are calculated from the amounts reported below.

44.6%$2,240 million
Additional provider payments

Payments above QPA in the analysis. This is not an administrative fee.

Reported amounts total $5.024B; rounding explains the “$5B” headline. Source: Hoadley & Watts, Health Affairs Forefront, August 2025, as cited in this guide.

Key Point

A key downside of using IDR to settle payment disputes is that the process is costly. Administrative fees plus internal costs are likely ultimately borne by consumers as higher premiums and cost-sharing.

Outcome Statistics

Provider win rates have remained consistently high and have actually increased over time.

81%

Provider Win Rate

2023

85%

Provider Win Rate

2024

More striking is how much providers are receiving relative to the Qualifying Payment Amount (QPA):

327%

Median Determination

of QPA, 2023

459%

Median Determination

of QPA, Q4 2024

Providers are submitting relatively high offers and IDR entities are selecting the provider's offer more than 75% of the time.

LA
Loren Adler

Fellow, Brookings Institution

Timeline Reality

The law requires IDR decisions within 30 business days. Reality tells a different story.

30

Statutory deadline (days)

81

Actual median, Q4 2024 (days)

Peak: 96 days in earlier periods

Eligibility & Coverage

Which claims qualify for IDR

Eligible Services

Not every out-of-network claim qualifies for IDR. The NSA covers specific categories of services.

Emergency Services

ER visits, stabilization, post-stabilization care when transfer impossible

Air Ambulance

Air ambulance services from OON providers (NOT ground ambulance)

Ancillary Services

OON providers at in-network facilities (anesthesia, radiology, pathology)

Excluded Claims

Warning

Ground ambulance services are NOT covered by the federal No Surprises Act IDR process. A separate Advisory Committee (which includes Loren Adler) is studying ground ambulance billing, but for now, these claims follow different rules that vary by state.

Claims NOT Eligible for Federal IDR:

  • Ground ambulance services
  • Medicare and Medicaid claims
  • Services where patient signed valid OON consent waiver
  • Claims in states with All-Payer Model (Maryland)
  • Coverage disputes (only payment amount disputes qualify)

State vs Federal Jurisdiction

The federal IDR process applies to most commercial insurance plans, but 22 states have their own "specified state laws" that may apply instead.

Pro Tip

About 65% of workers with employer coverage are in self-funded plans subject to federal IDR. Determining which rules apply is one of the first steps in building your case.

The IDR Process

Step by step from dispute to decision

Process Overview

The IDR process follows a structured timeline with specific requirements at each stage. Understanding each step is essential for maximizing your success rate.

Step-by-Step Walkthrough

PROCESS WALKTHROUGH · GUIDE SUMMARY

Follow the case through each stage.

STAGE 1 OF 8

Initial Payment

Payer issues initial payment (or denial) for OON claim. This starts the window to initiate open negotiation.

Triggers timeline

These are the guide’s summarized stages, not a deadline calculator. Rules and exceptions can change. Check the current CMS process guidance for a specific dispute.

Critical Deadlines

Warning

Missing any deadline can disqualify your case or significantly weaken your position. The 4-day window to initiate IDR is especially tight. Set calendar reminders and have documentation ready before the negotiation period ends.

Deadline Quick Reference

30

Start negotiation

After payment

4

Initiate IDR

Critical!

10

Submit offers

With evidence

30

Payment due

After decision

Understanding QPA

The controversial benchmark at the center of IDR

What is QPA?

The Qualifying Payment Amount (QPA) is a key benchmark in the IDR process. It represents the median contracted rate the payer has negotiated with in-network providers for the same or similar service in the same geographic area.

Key Point

QPA is the starting point, not the ending point. After the TMA lawsuits, arbitrators must consider QPA but are not required to anchor their decision to it. This is a critical distinction that courts have repeatedly upheld.

How QPA is Calculated

QPA Calculation Methodology

  1. 1

    Identify relevant contracts

    All in-network contracts for the service code

  2. 2

    Define geographic region

    Same metropolitan statistical area (MSA) or state

  3. 3

    Calculate median

    Median contracted rate under the applicable QPA methodology

  4. 4

    Annual indexing

    QPA is recalculated annually using CPI-U inflation

QPA Controversies

QPA methodology has been one of the most litigated aspects of the No Surprises Act. The Texas Medical Association's lawsuits have fundamentally challenged how QPA is calculated and used.

The federal rules permit insurers to include 'ghost rates' in their QPA calculations: contract rates with physicians who don't actually provide the particular health service.

TMA
Texas Medical Association

TMA III Allegations: QPA Problems

  • Contract rates for services never actually provided
  • Rates from physicians not in same/similar specialty
  • Amounts excluding contingent payments (bonuses, risk-sharing)
  • Rates from other self-insured plans

TMA III en banc hearing scheduled for 2025; outcome could reshape QPA rules

Winning Strategies

What separates successful cases from failures

Key Success Factors

With providers winning approximately 85% of decided IDR cases, success is achievable but not automatic. Research consistently shows certain factors correlate with better outcomes.

Verified Benchmark Data

Critical

Use actual payment data from similar providers, not just Medicare rates or billed charges

Complete Documentation

Critical

Every required element present and properly formatted. Missing docs give payers easy wins

Strategic Case Selection

High

Focus resources on cases with strong evidence; not every eligible claim should go to IDR

Clear Presentation

High

Make it easy for the arbitrator to understand your argument and find supporting evidence

Evidence Requirements

Arbitrators are legally required to consider specific categories of evidence. Your submission should address each of these factors comprehensively.

FactorWhat to Include
Provider QualificationsTraining, certifications, experience, subspecialty expertise
Market ShareProvider's presence and reputation in the geographic region
Patient AcuityComplexity of condition, comorbidities, severity of presentation
Service ComplexityTechnical difficulty, time required, resources utilized
Prior NegotiationsHistory of good faith contract negotiations with the payer

Strategic Case Selection

Not every eligible claim should go to IDR. Research from Georgetown CHIR shows that many disputes are filed without adequate evidence or case selection strategy.

Little evidence that rank-and-file emergency physicians, radiologists, and anesthesiologists are using the system. Four organizations accounted for ~2/3 of cases in Q2 2023.

JH
Jack Hoadley

Research Professor Emeritus, Georgetown CHIR

Clearest reports a 94% platform win rate on IDR cases

Company-reported metric. Eligibility and outcomes depend on the facts of each dispute.

Private Equity & IDR

The outsized role of PE-backed providers

PE Dominance in IDR

One of the most striking findings from academic research is the disproportionate role of private equity-backed provider groups in the IDR system.

The awards received through the NSA's independent dispute resolution process largely arise from disputes that are primarily initiated and won by private-equity-backed providers.

KW
Kennah Watts

Research Fellow, Georgetown CHIR

The Numbers

90%

PE-Backed Win Rate

vs. 39% for other ER groups

+63%

PE Premium

higher payments relative to QPA

Top IDR Initiators by Volume

OrganizationShare of Disputes
Radiology Partners28%
TeamHealth15%
Envision Healthcare~8%
SCP Health~8%
Top 5 providers combined59%

Source: Adler, Fiedler et al., Brookings 2024

Rise of Middlemen

A new development in the IDR landscape is the emergence of third-party IDR services that file disputes on behalf of providers.

HaloMD Growth

1%

of disputes, 2023

10%

of disputes, Q2 2024

Middlemen could give greater access to smaller provider organizations, but could also be driving higher volume of cases that increases systemwide costs.

TMA Lawsuit Victories: 4-0

The Texas Medical Association (TMA) has been the most consequential player in shaping IDR rules through litigation. They've won all four major lawsuits challenging the federal regulations.

TMA IOctober 2021
WON
Issue:

Challenged "rebuttable presumption" favoring QPA

Outcome:

Court struck down presumption; said it improperly tilted scales toward insurers

Impact:

Fundamental shift in how IDR entities weigh factors

TMA IISeptember 2022
WON
Issue:

August 2022 final rule still required "outsized weight" to QPA

Outcome:

Court vacated provisions favoring QPA (February 2023)

Impact:

QPA no longer presumptive winner; Fifth Circuit affirmed August 2024

TMA IIINovember 2022
PARTIAL WIN
Issue:

QPA calculation methodology allows "ghost rates" and manipulations

Outcome:

District court invalidated four provisions; Fifth Circuit panel reversed in part

Impact:

En banc hearing granted May 2025; could take ~1 year

TMA IVJanuary 2023
WON
Issue:

600% fee hike ($50 → $350) and narrow batching rules

Outcome:

Court struck down fee increase; vacated batching restrictions

Impact:

Restored access to IDR for smaller claims

Congress intended the NSA to be a fair means of protecting patients from surprise bills. Tilting the scales in favor of insurers was unfair to physicians, providers, and the patients we care for.

TMA
Texas Medical Association

Enforcement Crisis

A critical issue emerged in 2025 regarding whether IDR decisions are actually enforceable.

Circuit Split on Enforcement

Fifth Circuit (June 2025)

Ruled IDR awards NOT enforceable in federal court

Connecticut Court

Ruled the opposite: NSA makes IDR payments obligatory

Supreme Court declined to review, creating significant uncertainty for providers.

If the Fifth Circuit decision stands, Congress's scheme will be upended.

KK
Katie Keith

Director, Center for Health Policy and Law, Georgetown

Insurer Countersuits

In a significant escalation, major insurers began filing their own lawsuits against provider groups in 2024 and 2025.

Recent Insurer Actions

  • Elevance & Aetna lawsuits

    Suing provider groups over volume of "seemingly ineligible claims"

  • Fraud allegations

    Insurers claiming 39% of disputes ineligible (vs. 17% actually found so)

  • Elevance 10% penalty policy

    New controversial policy penalizing providers

They're really alleging a broad scheme of widespread fraud. It feels like a real escalation.

KK
Katie Keith

Director, Center for Health Policy and Law, Georgetown

Future Outlook

The IDR landscape will continue evolving. Key developments to watch:

Near Term (2025 to 2026)

  • • TMA III en banc decision (~1 year)
  • • Resolution of enforcement circuit split
  • • Potential Congressional action
  • • Ground ambulance advisory committee report

Longer Term

  • • Premium impact studies
  • • PE scrutiny and potential regulation
  • • IDR entity consistency standards
  • • State law harmonization

Key Research & Voices

The experts shaping IDR policy and analysis

Brookings Institution

LA

Loren Adler

Fellow & Associate Director, USC-Brookings Schaeffer Initiative

Member, Advisory Committee on Ground Ambulance and Patient Billing

Key Research Findings:

  • • Median IDR decision is at least 3.7× what Medicare would pay
  • • Emergency services IDR prices: 4.0× Medicare rates
  • • Imaging services IDR prices: 6.6× Medicare rates
  • • Four PE-backed companies generated 74% of line items in sample
MF

Matthew Fiedler, PhD

Joseph A. Pechman Senior Fellow, Economic Studies

Co-author of influential regulatory comments on QPA methodology

Georgetown CHIR

JH

Jack Hoadley, PhD

Research Professor Emeritus, Health Policy Institute

Former member, Medicare Payment Advisory Commission (MedPAC)

Key Research: "$5 Billion" Study

Landmark August 2025 analysis revealing the true costs of the IDR system, including additional provider payments, administrative costs, and system inefficiencies.

KW

Kennah Watts

Research Fellow, Center on Health Insurance Reforms

IDR entity analysis, dispute volume tracking, PE provider patterns

USC Schaeffer Center

ET

Erin Trish, PhD

Co-Director, USC Schaeffer Center; Nonresident Fellow, Brookings

Testified before U.S. House of Representatives and California State Assembly

Key Research Focus:

  • • Surprise medical bills and state law variations
  • • PE-backed provider behavior in IDR
  • • Market concentration effects on healthcare pricing

Resources & Glossary

Reference materials and next steps

Key Terms & Definitions

No Surprises Act (NSA)
Federal law effective January 2022 that protects patients from surprise medical bills and establishes the IDR process.
Independent Dispute Resolution (IDR)
The arbitration process for resolving payment disputes between providers and payers under the NSA.
Qualifying Payment Amount (QPA)
The median in-network rate a payer has contracted for similar services in the same geographic area.
IDR Entity
A certified, independent organization authorized to arbitrate disputes under the NSA.
Open Negotiation
The 30-day period after initial payment where parties attempt to resolve the dispute before IDR.
Baseball Arbitration
The IDR model where the arbitrator must select one party's offer in full with no compromise amounts.
Batching
Combining multiple similar claims into a single IDR dispute to improve efficiency.
ERISA
Employee Retirement Income Security Act. Governs self-funded employer health plans subject to federal IDR.

Get Expert Help

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Clearest helps independent practices assess eligible payment disputes, prepare evidence, and follow case progress. Discuss your claims with our team.

Sources: Brookings Institution, Georgetown CHIR, USC Schaeffer Center, Health Affairs, KFF, Texas Medical Association, CMS, Fifth Circuit Court of Appeals
Last updated: January 2026

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