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No Surprises Act

Out of network surgical claims denied or underpaid?Federal IDR, by code, state, payer, and specialty.

Out of network surgical claims are routinely paid below the billed charge or denied outright. Find your procedure, state, and payer to see why these claims get denied and how federal IDR recovers the gap. We build the submission and you keep the recovery.

New to this? Start with what federal IDR is.

The federal record.

The published federal IDR record across all disputes. These are aggregate federal figures, sourced and dated, not a prediction about any one claim.

88%
Providers win about 88 percent of properly filed federal IDR disputes.
CMS Federal IDR Public Use Files; Georgetown University CHIR analysis. As of H1 2025.
85%
Providers prevailed in about 85 percent of determinations in 2024.
Congressional Research Service R48738. As of 2024.
88%
In about 88 percent of determinations, the prevailing offer beat the qualifying payment amount.
CMS Federal IDR Public Use Files. As of 2024 to 2025.
up to 1,700%+
Surgical disputes have awarded roughly 970 percent to over 1,700 percent of the qualifying payment amount across recent reporting periods.
CMS Federal IDR Public Use Files; CRS R48738; Georgetown CHIR. As of 2024 to 2025.
1,200%+
Neurology and neuromuscular disputes have awarded over 1,200 percent of the qualifying payment amount.
CMS Federal IDR Public Use Files; Georgetown CHIR. As of 2024.
~257%
Emergency disputes award far smaller multiples, around 257 percent of the qualifying payment amount, which is why the aggregators crowd that lane and surgery stays open.
Georgetown CHIR; CMS PUF. As of H1 2024.
~559% to 594%
Radiology disputes award around 559 to 594 percent of the qualifying payment amount.
Georgetown CHIR; CMS PUF (Radiology Partners cohort). As of 2024 to 2025.
~4.8 million
About 4.8 million disputes were filed through the end of 2025, against the roughly 17,000 per year Congress expected. Most eligible claims are never disputed.
Georgetown CHIR; CMS bimonthly updates. As of through Dec 2025.
~9%
Surgery and neurology together were only about 9 percent of resolved cases, yet they win the largest multiples in the dataset.
Georgetown CHIR. As of 2024.
~65%
About 65 percent of covered workers are in self funded plans, which always route to federal IDR regardless of state.
Peterson KFF Health System Tracker. As of 2021 baseline.
3 years
New York lets providers challenge commercial payments going back three years, so claims written off as dead can be revived.
New York surprise bill law; practitioner analyses. As of 2025.
22 states
About 22 states have a specified state law that can govern fully insured disputes instead of the federal process.
Commonwealth Fund. As of 2024 to 2025.
4 business days
After the 30 business day open negotiation period, a provider has only four business days to initiate IDR or the claim is lost.
CMS No Surprises Act IDR guidance. As of 2026.

No outcome is guaranteed. Results vary by claim, payer, specialty, and documentation. Any general figures reflect the published federal record across all disputes, not a prediction about your claim. This is general information, not legal or financial advice.

Guides.

How the federal IDR process works for surgical practices.

Sourced references
  1. 1. CMS Federal IDR Q1/Q2 2025 Public Use FileReleased January 21, 2026cms.gov/nosurprises/policies-and-resources/reports
  2. 2. Georgetown University CHIR · Health Affairs webinarMarch 2026 — 3.4 million disputes through June 2025; 88% win rate; median award ~4.5x in network rate
  3. 3. Zelis — NSA IDR Eligibility ChallengesMarch 2026 — 44% of 2024 IDR cases challenged as ineligible by non initiating party
  4. 4. ACEP analysis of CMS data~10% of eligible claims estimated to reach IDR arbitration
  5. 5. Brookings Institution NSA Arbitration DatabookApril 2026brookings.edu/articles/no-surprises-act-arbitration-databook
  6. 6. ACR — Providers Prevail in Vast Majority of IDR ClaimsJanuary 2026 — 88% of disputes found in provider's favor; 87% of awards exceeded QPA
  7. 7. No Surprises Act: Public Law 116-260, Division BB, Title I
  8. 8. Federal IDR regulations: 45 CFR Part 149ecfr.gov/current/title-45/subtitle-A/subchapter-F/part-149
  9. 9. CMS No Surprises Act overviewcms.gov/nosurprises
  10. 10. HHS HIPAA for professionalshhs.gov/hipaa/for-professionals

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