The independent dispute resolution process created under the No Surprises Act has generated at least $5 billion in costs since it took effect in 2022, according to a study published Aug. 25 in Health Affairs.
Here are five takeaways from the study:
1. The costs are largely due to high dispute volumes and providers winning the majority of disputes from 2022 to 2024. Administrative costs accounted for more than half of the overall amount, at $2.8 billion.
2. In 2023 and 2024, IDR awards required insurers to pay providers $2.24 billion above the in-network rates reflected by the qualifying payment amounts. In many cases, awards were three to four times the QPA.
3. Federal regulators initially projected that about 17,000 disputes would take place annually. However, from mid-2022 to May 2025, more than 3.3 million disputes were filed, including air ambulance cases. As of May 2025, 85% have been closed, but nearly 500,000 disputes remain pending.
4. In 2024, providers won 85% of disputes. Median payment determinations were 459% of QPA in the fourth quarter of 2024, up from 327% in 2023. Some organizations, such as HaloMD, won awards at 934% of QPA. There have since been numerous lawsuits between payers and provider groups regarding the IDR process and award amounts.
5. Radiology Partners and Team Health accounted for 43% of resolved line-item claims in 2023 and 2024. The top five providers make up 59% of claims, with cases concentrated in Texas, Florida, Tennessee and Arizona.
