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The No Surprises Act

Federal IDR data:
compare the reported QPA with market rates.

Review CMS payment determinations and compare a payer's reported QPA with published negotiated rates for the same service code and market.

Published July 17, 2026 · Updated July 20, 2026 · Prepared by PayerPrice Research · CMS data through 2025-Q2

Market percentiles use published rates for the same service code.

5.3Mdetermined line items
85%provider-favorable line items
10quarters analyzed
2025-Q2latest detailed CMS data
Source · CMS Federal IDR public-use files · line-item-level analysis · data through 2025-Q2
How to read these numbersCMS publishes one row per determined item or service. Batched disputes can contain multiple rows, so this page reports determined line items, not unique disputes. Provider-favorable rates include default decisions. This analysis covers OON emergency and non-emergency determinations, not the separate air ambulance file. Detailed data currently run through 2025-Q2.Read the methodology
The offers

How the offers compare with the QPA

The chart shows median offers from the most recent quarter as a percentage of the QPA. It also shows the difference between the provider offer and the plan offer when the IDR entity made its selection.

Median values for 2025-Q2, each as a percentage of the QPA benchmark (the plan's median contracted rate). The prevailing offer is the one the entity selected as the binding payment.
How it works

How a payment dispute gets settled

Federal IDR is a form of final-offer arbitration. The certified IDR entity must select one of the two submitted offers. The process moves from open negotiation to a binding payment in four steps.

  1. 1Open negotiation failsAfter an out-of-network bill, the provider and plan get 30 business days to agree on payment. If they can't, either side can start the IDR process.
  2. 2An IDR entity is chosenThe parties pick a certified IDR entity (the arbitrator) together. If they can't agree on one, the government assigns it at random.
  3. 3Each side submits one offerThe plan calculates and reports the QPA; each party chooses a final payment offer and may submit permitted information supporting it.
  4. 4The entity selects an offerThe certified IDR entity chooses one submitted amount as the binding payment. The prevailing party's entity fee is returned; both parties bear the separate administrative fee.
The scale

Determined volume rose sharply

When the process launched, regulators anticipated about 22,000 disputes in 2022. Instead, parties filed nearly 490,000 through June 2023. The detailed CMS files now contain 5.3M determined line items. Each bar is a quarter of determined line items; the line is the share with a provider-favorable reported outcome.

QuarterDetermined line itemsProvider-favorable
2025-Q21,632,67587%
2025-Q11,114,67187%
2024-Q4947,21086%
2024-Q3660,85583%
2024-Q2377,78580%
2024-Q1186,53185%
2023-Q478,43882%
2023-Q376,54079%
2023-Q2113,11777%
2023-Q165,26968%

Provider-favorable - share of determined line items reported in favor of the provider, facility, or air ambulance provider. It includes defaults and is not a contested-case win rate.

Sources: U.S. GAO, GAO-24-106335 (Dec. 2023) for the 2022 projection and disputes filed through June 2023; CMS Federal IDR public-use reports for dispute counts and outcomes.

Who & where

Who ends up in arbitration, and where

A relatively small number of payers, provider email domains, and states account for much of the determined line-item volume. For payer-specific contracting context, see our payer rate guides.

Payers with the most determined line items

#PayerLine itemsProvider-favorable
1United Healthcare (incl Optum, Rocky Mountain, Health Plan of Nevada, Sierra Health)1,607,83983%
2Aetna1,004,46093%
3Cigna738,99581%
4BCBS Texas616,96986%
5Unknown350,20381%
6Elevance (Anthem)246,38787%
7BCBS Arizona130,82473%
8BCBS Florida Blue99,33294%
9BCBS Tennessee84,23379%
10Ambetter72,00990%

Provider email domains with the most determined line items

This is the provider contact's reported email domain, not proof of which party initiated the dispute. A domain may belong to the provider organization or a billing or IDR representative.

#Provider email domainLine itemsProvider-favorable
1saparm.com680,87493%
2teamhealth.com582,96793%
3halomd.com459,34287%
4envisionhealth.com334,18681%
5fam-llc.com267,22683%
6totalcare.us217,75976%
7bmhcc.org160,34786%
8sonoranrm.com174,61189%
9agshealth.com212,35284%
10primehealthcare.com205,77692%

Top states by determined line-item volume

StateLine itemsProvider-favorable
TX2,080,32086%
AZ467,02382%
FL470,14887%
TN314,13983%
NY179,51885%
GA177,73683%
NJ163,36184%
IN119,90487%
CA119,04989%
VA100,24885%
From QPA to market context

Compare the reported QPA with published market rates

PayerPrice compares a reported QPA with published negotiated-rate percentiles by payer, service code, and market. Teams can review relevant IDR outcomes alongside that benchmark.

Benchmark the reported QPA

Compare the reported QPA with published negotiated-rate percentiles for the same service code and market.

Compare payers code by code

Compare market percentiles across payers for the codes that matter instead of relying on one blended benchmark.

Inform offer strategy

Use like-for-like rate context alongside IDR outcomes to evaluate a reported QPA and prepare a more grounded offer strategy.

Schedule a demo A guided walkthrough uses a payer, service code, and reported QPA to show the market position.
How they end

Outcomes and IDR fees

The IDR entity selects one of the submitted offers. Both parties generally pay the entity fee up front. After the decision, the fee is returned to the prevailing party, while the non-prevailing party bears that cost. The separate federal administrative fee is not refunded.

In Favor of Provider/Facility/AA Provider85%
4,470,727 determined line items
In Favor of Plan/Issuer15%
778,135 determined line items
Split Decision0%
4,115 determined line items
Unknown0%
114 determined line items
Methodology

How to read this analysis

PayerPrice parses and normalizes the CMS Federal IDR public-use files, then aggregates determined line items by quarter, payer, provider email domain, state, and reported outcome through 2025-Q2. The public files do not provide a reliable way to identify and deduplicate unique disputes. This analysis therefore reports line-item counts, not counts of unique disputes.

  • Unit of analysis is the determined line item. Batched and bundled disputes can contribute multiple line items.
  • Provider-favorable rate includes reported provider/facility wins, including defaults; it is not a contested-case win rate.
  • Offers and awards are summarized against the reported QPA. Batched disputes and missing fields can affect comparisons.
  • IDR entity compensation can repeat across line items in a batch, so this page does not sum it into payer, filer, or state fee totals.
  • Timing is not compared across years because CMS changed the Length of Time methodology for the 2025 files.
  • Federal scope does not cover every out-of-network claim. State payment rules may govern some plans, services, and disputes instead.
  • Limitations in the CMS source files, including reporting gaps or later corrections, carry through to these aggregates.
Sources

Primary sources & further reading

Outcome and offer figures come from CMS's public Federal IDR data. Historical projections and rollout context are cited separately. These are the primary government sources behind the analysis.

Questions

Common questions about IDR data

What is IDR data?

CMS's detailed IDR public-use files contain line-item-level records for items and services that reached a federal payment determination. They include reported parties, offers, outcomes, IDR entity compensation, and timing fields. A batched dispute can contribute more than one line item.

How often are IDR line items decided in favor of providers?

Across the detailed federal data analyzed here, roughly 85% of determined line items have a provider-favorable reported outcome. That aggregate includes default determinations, so it is not a contested-case win rate. Results also vary by quarter, payer, and service.

Who pays the IDR entity fee?

Both parties generally pay the certified IDR entity fee when the entity is selected. After the determination, the entity returns that fee to the prevailing party, so the non-prevailing party ultimately bears it. The separate federal administrative fee is paid by both parties and is not refunded.

Does federal IDR apply in every surprise-billing dispute?

No. The federal process covers qualifying out-of-network services governed by the No Surprises Act. A state's payment or dispute-resolution rules may apply instead for some services and plans, and the public files separately cover air ambulance and other applicable dispute types.

Where does PayerPrice get IDR data?

From CMS's public IDR datasets, parsed and normalized into a structured, queryable schema alongside our price transparency rate data.

Can PayerPrice compare IDR outcomes with negotiated rates?

Yes. PayerPrice can analyze IDR records alongside published negotiated-rate data at the service-code level and show market percentiles across payers. This adds context that is not available from either dataset alone.

Can PayerPrice calculate or select the official QPA?

No. The plan calculates and reports the official QPA under the applicable rules; disputing parties do not select it. PayerPrice benchmarks the reported QPA against published negotiated-rate percentiles for comparable payer, code, and market combinations. Those transparency rates provide market context but do not recreate the official QPA.

What does the IDR analytics walkthrough show?

The walkthrough uses a payer, service code, and reported QPA to show the relevant published market percentiles, comparisons with other payers, and related IDR outcomes. IDR analytics are not included in the self-service trial.

Next step

Put the reported QPA in market context

Compare the reported QPA with published negotiated rates for the same service code and review percentiles across payers alongside related IDR outcomes.

Schedule a demo
The walkthrough uses a payer, service code, and reported QPA to show the relevant market percentile and IDR outcomes. Published rates provide context; they do not recreate the official QPA. IDR analytics are not included in the self-service trial.
Data source · CMS Federal IDR public-use files. Figures update as new quarters are published and may contain reporting errors inherent to the source files.