Federal IDR in 2025: 2.6 Million Disputes, 20,000 Expected

When the No Surprises Act created the federal independent dispute resolution process, federal officials expected roughly 17,000 to 22,000 disputes per year. According to analyses of CMS public use files, providers initiated about 2.6 million disputes in 2025 alone. The first half of 2026 added another 1.75 million, up roughly 50 percent from the same period a year earlier.

The system is operating at more than one hundred times its designed capacity. That fact shapes everything else about how IDR works in practice: timelines, backlogs, and what it takes for a filing team to keep its evidence straight.

Volume is concentrated, not spread out

This is not a broad, evenly distributed problem. Emergency medicine accounted for 52 percent of all payment determinations in the second half of 2025, with radiology next at 15 percent. Across 2023 through 2025, emergency medicine and radiology together were the majority of dispute filings, and anesthesiology ranked fifth among provider types by line-item volume.

Initiator concentration is even starker. The top 10 initiating parties account for roughly 67 percent of all cases. The top four, HaloMD, TeamHealth, SCP Health, and Radiology Partners, filed 56 percent of all disputes in the first half of 2025. Most high-volume filers are private-equity-backed provider organizations or third-party filing operations.

Providers are winning. The record is the risk.

Providers won 88 percent of payment determinations in the first half of 2025, the highest win rate recorded to date, and about 85 percent in the second half. In roughly 87 percent of determinations, the prevailing offer exceeded the qualifying payment amount.

The win rate is not the problem for filing teams. The evidence record underneath it is. When a process handles millions of cases, it handles them fast, and fast systems reward clean, consistent packets. A team assembling evidence reviewer by reviewer, with no consistent record underneath, carries rework risk on every filing, and that risk compounds at volume.

What this means for revenue cycle teams

• Know your CMS numbers. Dispute counts by initiating party are public. If your team cannot pull its own 12-month filing count in one lookup, that is the first gap.
• Standardize the evidence structure. Permitted-factor evidence should look the same no matter which reviewer assembled it.
• Check batching and deadlines before filing. Exceptions discovered late are the most expensive kind of rework.
• Make the record reproducible. Every factor should trace to its exact source text, with reviewer signoff preserved.

We built Logic Refinery IDR-A for provider-side teams filing at exactly this scale: a pre-filing evidence and readiness layer that sits beneath the existing workflow. It does not file disputes, decide eligibility, calculate QPA, or replace the reviewer. Your team makes the decisions. We make them defensible.