Federal IDR statistics (2026)

Dispute volume

• 5.1 million+ — federal IDR disputes submitted through January 31, 2026.
• Volume has run orders of magnitude above the level the Departments projected when the process launched, which is the root cause of the eligibility-review backlog.

Outcomes

• ~88% — share of determinations reaching a decision that are resolved in the provider's favor.
• Federal IDR is baseball-style: the certified entity must select one of the two submitted offers and cannot split the difference or substitute its own figure.
• The win rate applies only to disputes reaching determination. Disputes closed as ineligible never reach that stage, so it is not a filing-level success rate.

Costs

• $15 — administrative fee per party per dispute, reduced from $115 by the final rule published June 4, 2026 (CMS-9897-F).
• $200-$840 — certified IDR entity fee range, single determination.
• $268-$1,173 — certified IDR entity fee range, batched determination.

Batching

• 50 — maximum line items in a single batched dispute.
• Conditions: same payer, same or related service codes, consecutive-day items. The 2026 rule widened these conditions from the prior standard.

Timelines

• 30 business days — window to initiate open negotiation after the initial payment or denial.
• 30 business days — length of the open negotiation period.
• 4 business days — window to initiate IDR after open negotiation closes.
• 3 business days — window for the parties to agree on a certified IDR entity.
• 5 business days — eligibility review deadline imposed on certified entities by the 2026 rule.
• 10 business days — deadline for offers and supporting documentation after entity selection.
• 30 business days — deadline for the determination after entity selection.
• 30 business days — deadline for payment after the determination.

State landscape

• 22 — states with surprise-billing protections.
• 21 — states using some form of bifurcation between state and federal process.
• Pennsylvania has no comprehensive state surprise-billing law; claims there route to federal IDR.

What is not disputable

Ground ambulance services remain outside the federal No Surprises Act balance-billing protections and are not eligible for federal IDR. Claims covered by a qualifying state process go to that process rather than the federal one.

Sources: CMS Federal IDR public use files and reports; CMS-9897-F final rule published in the Federal Register June 4, 2026. Last reviewed September 9, 2026. Figures are updated as new CMS reporting periods are released.