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IDR data & benchmarks

What No Surprises Act IDR disputes actually pay.

Public data from the CMS Federal IDR reports, summarized for providers deciding whether to file. Updated as new public use files are released.

2.6M
disputes initiated in 2025 (≈1.2M in H1, ≈1.4M in H2) — nearly double 2024
85–88%
of payment determinations decided in favor of the provider (88% H1, 85% H2)
$14.9B
total IDR payouts to providers in 2025, vs. $4.1B in 2024
87%
of H1 2025 awards exceeded the payer's QPA

Median awards as a multiple of QPA

CategoryQ3 2025Q4 2025Notes
Emergency services324%296%~633k determinations in H2; largest category (~52% of disputes)
Surgery1,449%1,279%~238k determinations; often low-dollar QPAs
Neurology / neuromuscular2,394%1,938%~160k determinations; highest ratios in the program
Radiology——~15% of disputes; medians vary widely by modality

Source: CMS Federal IDR Q3–Q4 2025 public use files and supplemental tables, as reported by HFMA, Health Affairs, and CMS. Ratios are medians across all decided disputes and are not a prediction for any specific claim.

What this means for a group deciding whether to file

  • The QPA is the payer's opening position, not the market rate. Determinations reflect that.
  • Volume matters: emergency and radiology groups can batch large numbers of similar claims, keeping per-dispute cost low.
  • Ineligible filings are the main way providers waste money — 42% of H2 2025 disputes were challenged as ineligible. Screening is the highest-value step.
  • Speed has improved: about 62% of determinations in H2 2025 were issued within 30 business days, up from 37% in H1.
  • Concentration is high — the top three initiating parties accounted for roughly 44% of all disputes in H1 2025. Most independent groups are not filing at all.

Program changes to watch

The federal IDR operations rule finalized in 2026 revised eligibility review, batching, communication requirements, and reduced the administrative fee. We update our screening rules on each change and note it here.

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