Federal IDR · Case Study
Anatomy of a Dispute: The Concentration Game
Of the 2,225,089 distinct provider-initiated disputes in the 2025 public data, filed under 12,323 different group names, the top 10 filing organizations account for roughly 1.37 million disputes. Sixty-two percent. Ten filers out of twelve thousand control nearly two-thirds of all federal IDR volume.
The largest single filer, HaloMD, filed 407,379 disputes. Not as a provider. As an intermediary, filing on behalf of more than 150 client groups. TeamHealth filed 292,536 across its subsidiaries. AGS Health, an RCM firm, filed 98,276.
The top 10 filing organizations account for roughly 1.37 million of 2,225,089 distinct provider-initiated disputes in 2025. (Author analysis of CMS PUF 2025 Q1-Q4.)
What concentration means
This is not a market of twelve thousand equal participants. It is a market with a thin layer of industrial-scale filers on top and a long tail of everyone else underneath. And the industrial layer did not get there by hiring more paralegals. It got there by systematizing the dispute pipeline: intake, eligibility screening, evidence assembly, offer calibration, submission, tracking. At 400,000 disputes a year, there is no other way. Manual process does not scale to that volume.
Consider what that means for a mid-size group filing 5,000 disputes a year. They are not competing against the plan's lawyers. They are competing against filing machines that have turned the entire process into a production line, where every dispute gets the same rigorous evidence treatment because the system enforces it, not because someone remembered to.
The 90 percent rule
Ask anyone operating at this scale how the work actually gets done and the answer is consistent: the consultancy is the face, but automation is the engine. Roughly 90 percent of the dispute process, intake through submission, is systematizable. What remains is judgment: the calibrated offer, the evidence strategy for the hard cases, the human reviewer who signs off before anything goes out.
The groups losing at volume are not losing because their cases are weaker. They are losing because they are running a craft process against an industrial one.
The takeaway
Volume without system is just expensive losing. If you are filing thousands of disputes a year on manual processes, you are donating margin to organizations that automated the boring parts years ago. The evidence package is the product. Build it like one: source-traced, sealed, complete, every single time, with human judgment reserved for where it actually matters.
Sources
- Paragon Health Institute analysis of CMS Federal IDR public use files: Fixing the No Surprises Act
- Georgetown Center on Health Insurance Reforms, via Fierce Healthcare: costs tied to the No Surprises Act IDR process
- Health Affairs Forefront, early look at 2025 IDR data: No Surprises Act IDR process
- Becker's Payer Issues, H1 2025 determinations: providers won 88%
- Becker's Payer Issues, dispute volume growth: volume grows, costs pass $22B
- Radiology Business, specialty determination shares: radiology fires back
- CMS Federal IDR reports and public use files: independent dispute resolution reports
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Get Your Free ScorecardTen filers out of 12,323 control 62% of all federal IDR volume. What industrial-scale filing looks like, and why craft processes lose to it.
This post is educational, not legal advice. Run IDR strategy past your own counsel before you rely on it.
