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No Surprises Act IDR disputes, by the numbers

When an insurer and a provider can't agree on an out-of-network bill, the No Surprises Act sends them to independent dispute resolution (IDR): binding arbitration where each side offers a price and the arbiter picks one. CMS publishes every dispute line item. Below: all 1,632,680 dispute line items from the federal IDR public use file, 2025 Q2 edition (cumulative since the process began in 2022).

1,632,680
dispute line items filed through Q2 2025
86.8%
decided in favor of the provider
13.1%
decided in favor of the plan or insurer
1,188
split decisions

What this means for a patient

Two facts matter if you got a surprise bill. First, the dispute is between the provider and the insurer, not you: once a qualifying service enters IDR, federal law bars the provider from billing you beyond in-network cost sharing while the dispute is open. Second, providers win overwhelmingly, which tells you insurer initial offers in these disputes are often below what an independent reviewer thinks is fair. If a provider is coming after you for the balance of a surprise emergency or facility bill, that bill likely qualifies for No Surprises Act protections and should not exist.

Most frequent insurers in IDR

InsurerDispute itemsProvider won
UnitedHealthcare (incl. UMR)388,27387%
Aetna245,37993%
Cigna101,68678%
Blue Cross And Blue Shield Of Texas77,32588%
Bcbstx57,44296%
Cigna Healthcare52,36595%
Bcbs Of Texas37,99090%
Bluecross Blueshield Of Texas32,86688%
Bcbs Of Tx30,34689%
Aetna Health Plans23,32382%
Anthem Blue Cross Blue Shield20,97982%
Blue Cross Blue Shield Of Arizona15,83787%
Blue Cross15,65391%
Umr, Inc.14,74297%
Florida Blue12,89698%
Bcbs12,83582%
Cigna Health And Life Insurance Company12,64974%
Unitedhealthcare Uhc11,87778%
Uhc11,48169%
Blue Cross Blue Shield Of Texas10,65897%

Where the disputes are

StateDispute items
Texas718,984
Arizona144,015
Florida115,890
Tennessee70,191
New York49,660
California48,955
Georgia46,362
New Jersey42,293
Indiana42,151
Oklahoma28,913
Ohio25,637
Arkansas25,514
Nevada23,643
Missouri20,186
Louisiana18,761

Texas alone accounts for about 44% of all disputes: a high uninsured-adjacent share of facility billing plus aggressive ER and air-ambulance arbitration practice. Source: CMS Federal IDR Public Use File, 2025 Q2 (as of January 21, 2026).

Frequently asked

What is the No Surprises Act IDR process?

Independent dispute resolution is the binding arbitration process created by the No Surprises Act: when an out-of-network provider and a health plan cannot agree on payment for a qualifying service, each submits an offer and a certified independent arbiter picks one. CMS publishes the outcomes quarterly.

Who wins most IDR disputes?

In the CMS public use file through Q2 2025, decisions favored providers about 87% of the time versus about 13% for plans and insurers, with a small number of split decisions. The lopsided split is one of the most-studied findings in the program.

Can I be billed while my surprise bill is in dispute?

No. For services protected by the No Surprises Act, the provider may only bill you in-network cost sharing while the dispute is pending. If you are being balance-billed for a qualifying emergency or facility service, that billing violates the rule and you can appeal or complain to your state and CMS.

Does this apply to employer plans?

It applies to most group health plans and issuers for emergency services, air ambulance, and certain facility-based services from out-of-network providers. Disputes that do not qualify go to state law instead.