Independent dispute resolution reports

Independent Dispute Resolution Reports

The No Surprises Act (NSA) and its implementing regulations establish a Federal Independent Dispute Resolution (IDR) process that out-of-network (OON) providers, facilities, and providers of air ambulance services, and group health plans, health insurance issuers in the group and individual markets, and Federal Employees Health Benefits (FEHB) Program carriers (collectively, the disputing parties) may use to determine the OON rate for qualified IDR items or services after an unsuccessful open negotiation period. 

The Departments of Health and Human Services, Labor, and the Treasury (the Departments) launched the Federal IDR portal on April 15, 2022, to facilitate this process. The statute requires the Departments to publish on a public website certain information about the Federal IDR process. To promote transparency in the implementation of the Federal IDR portal, the Departments are sharing the below data with the public. 

Federal IDR public use files (PUF)

For more information about the Federal IDR Public Use Files (PUF), please review the below documentation that was updated on May 28, 2025: 


Federal IDR bi-monthly reports

In an effort to provide more transparency with respect to the current operations of the Federal IDR process, the Departments are now also releasing additional information on a bi-monthly basis to update the public more frequently on IDR program statistics. This bi-monthly update is not intended to be a substitute for the more comprehensive release of IDR information in the IDR PUFs and Federal IDR supplemental tables released by the Departments as required under the statute. The Departments will continue to release the IDR PUFs and supplemental tables. 

This first release of data in advance of the release of the 2025 Q1 and Q2 IDR PUFs shows that certified IDR entities are making significant progress in improving the overall Federal IDR process, closing more disputes in 2025 than have been initiated to date this year. In other words, certified IDR entities are keeping pace with rising dispute volume in 2025 and also steadily working through the high volume of disputes that had been initiated in prior months.  

In May 2025, 209,637 disputes were initiated, a decrease of 7% over April 2025 (225,622). 

The Federal IDR program dispute closure volume continues to rise month over month. Certified IDR entities closed 264,805 disputes in May 2025, 8% more than April 2025 (244,705) and 26% more than were initiated in May (209,637).  
 

Table 1: Disputes initiated from April 15, 2022 to May 31, 2025

Number of Disputes Initiated, April 1, 2025 – May 31, 2025Number of Disputes Initiated, CY 2025Number of Disputes Initiated, April 15, 2022 – May 31, 2025

435,259

980,681

3,324,051


Table 2: Reasons for closure of disputes from April 15, 2022 to May 31, 2025

Closure ReasonNumber of Disputes Closed, April 1, 2025 – May 31, 2025Number of Disputes Closed, CY 2025Number of Disputes Closed, April 15, 2022 – May 31, 2025
Payment Determination

413,466

879,879

2,152,045

Found Ineligible

82,976

186,286

539,664

Other*

13,068

31,605

140,095

Total Closed Disputes

509,510

1,097,770

2,831,804


*The “Other” closure reason category represents disputes that were either withdrawn by disputing parties, closed due to outside settlement between the disputing parties, or were closed for administrative reasons, such as data entry errors or the failure of both parties to pay fees or submit offers.

 

 

 

Page Last Modified:
06/24/2025 02:17 PM