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 PUF General Information (PDF)
- Federal IDR Supplemental Tables General Information (PDF)
- Federal IDR PUF Data Dictionary (XLSX)
- Federal IDR PUF Data Disclaimer—User Agreement (PDF)
- 2024 Reporting Year
- Federal IDR PUF for 2024 Q1 (as of March 18, 2025) (XLSX)
- Federal IDR PUF for 2024 Q2 (as of March 18, 2025) (XLSX)
- Federal IDR PUF for 2024 Q3 (as of May 28, 2025) (XLSX)
- Federal IDR PUF for 2024 Q4 (as of May 28, 2025) (XLSX)
- Federal IDR Supplemental Tables for 2024 Q1 (as of March 18, 2025) (XLSX)
- Federal IDR Supplemental Tables for 2024 Q2 (as of March 18, 2025) (XLSX)
- Federal IDR Supplemental Tables for 2024 Q3 (as of May 28, 2025) (XLSX)
- Federal IDR Supplemental Tables for 2024 Q4 (as of May 28, 2025) (XLSX)
- Supplemental Background on the Federal IDR PUF, January 1 - June 30, 2024 (as of March 18, 2025) (PDF)
- Supplemental Background on the Federal IDR PUF, July 1 - December 31, 2024 (as of May 28, 2025) (PDF)
- 2023 Reporting Year
- Federal IDR PUF for 2023 Q1 (as of February 15, 2024) (XLSX)
- Federal IDR PUF for 2023 Q2 (as of February 15, 2024) (XLSX)
- Federal IDR PUF for 2023 Q3 (as of June 13, 2024) (XLSX)
- Federal IDR PUF for 2023 Q4 (as of June 13, 2024) (XLSX)
- Federal IDR Supplemental Tables for 2023 Q1 (as of February 15, 2024) (XLSX)
- Federal IDR Supplemental Tables for 2023 Q2 (as of February 15, 2024) (XLSX)
- Federal IDR Supplemental Tables for 2023 Q3 (as of June 13, 2024) (XLSX)
- Federal IDR Supplemental Tables for 2023 Q4 (as of June 13, 2024) (XLSX)
- Supplemental Background on the Federal IDR PUF, January 1 - June 30, 2023 (as of February 15, 2024) (PDF)
- Supplemental Background on the Federal IDR PUF, July 1 - December 31, 2023 (as of June 13, 2024) (PDF)
- Federal Independent Dispute Resolution Process—Status Update (April 27, 2023) (PDF)
- 2022 Reporting Year
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.
- As of May 31, 2025
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, 2025 Number of Disputes Initiated, CY 2025 Number 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, 2025Closure Reason Number of Disputes Closed, April 1, 2025 – May 31, 2025 Number of Disputes Closed, CY 2025 Number 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.