In January 2026, the Centers for Medicare & Medicaid Services (CMS) published the Federal Independent Dispute Resolution (IDR) Public Use Files (PUFs) and supplemental tables for the first and second quarters of 2025. These datasets provide transparent, detailed information on dispute activity under the No Surprises Act (NSA), the federal law designed to protect patients from unexpected out-of-network medical bills.
The IDR process applies when clinicians and payers cannot agree on a payment amount for out-of-network (OON) services after open negotiation and instead request arbitration by a certified independent entity. Early analysis indicates that clinicians continue to prevail in the vast majority of disputes, with about 88% of determinations favoring the clinician and most award amounts exceeding the insurer’s qualifying payment amount (QPA).
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