Independent Dispute Resolution Reports

The No Surprises Act (NSA) and its implementing regulations established 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: 

2024 Reporting Year
2023 Reporting Year
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 release 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. Beyond simply keeping pace with rising dispute volume in 2025, certified IDR entities are 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

Number of Disputes Initiated, April 1, 2025 – May 31, 2025Number of Disputes Initiated, January 1, 2025 – May 31, 2025Number of Disputes Initiated, April 15, 2022 – May 31, 2025

435,259

980,681

3,324,051


Table 2: Reasons for Closure of Disputes

Closure ReasonNumber of Disputes Closed, April 1, 2025 – May 31, 2025Number of Disputes Closed, January 1, 2025 – May 31, 2025Number 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 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.

As of July 31, 2025

In July 2025, 213,585 disputes were initiated, an increase of 4% over June 2025 (206,131).

The Federal IDR program dispute closure volume continues to rise month over month. Certified IDR entities closed 263,350 disputes in July 2025, 4% more than June 2025 (252,422) and 23% more than were initiated in July 2025 (213,585). 

 

Table 1: Disputes Initiated

Number of Disputes Initiated, June 1, 2025 – July 31, 2025Number of Disputes Initiated, Jan 1, 2025 – July 31, 2025Number of Disputes Initiated, April 15, 2022 – July 31, 2025

419,716

1,400,397

3,743,767

 

Table 2: Reasons for Closure of Disputes

Closure ReasonNumber of Disputes Closed, June 1, 2025 – July 31, 2025Number of Disputes Closed, Jan 1, 2025 – July 31, 2025Number of Disputes Closed, April 15, 2022 – July 31, 2025
Payment Determination

412,476

1,291,236

2,562,612

Found Ineligible

91,684

277,403

630,428

Other*

11,612

43,150

151,576

Total Closed Disputes

515,772

1,611,789

3,344,616

*The “Other” closure reason category represents disputes that were 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.

As of September 30, 2025

In September 2025, 219,234 disputes were initiated, a decrease of 1% over August 2025 (220,626). 

From August 2025 to September 2025, both initiations and closures declined slightly, but the number of dispute closures continued to exceed initiations, as certified IDR entities worked to clear the remaining IDR backlog. Certified IDR entities closed 240,579 disputes in September 2025, 10% more than were initiated in September 2025 (219,234), and 6% less than were closed in August 2025 (256,542). 

 

Table 1: Disputes Initiated

Number of Disputes Initiated, August 1, 2025 – September 30, 2025 

Number of Disputes Initiated, January 1, 2025 – September 30, 2025 

Number of Disputes Initiated, April 15, 2022 – September 30, 2025 

439,860 

1,840,257 

4,183,627 

 

Table 2: Reasons for Closure of Disputes

Closure Reason 

Number of Disputes Closed, August 1, 2025 – September 30, 2025 

Number of Disputes Closed, January 1, 2025 – September 30, 2025 

Number of Disputes Closed, April 15, 2022 – September 30, 2025 

Payment Determination 

393,830 

1,684,567 

2,955,772 

Found Ineligible 

89,257 

365,629 

718,396 

Other* 

14,034 

57,112 

165,514 

Total Closed Disputes 

497,121 

2,107,308 

3,839,682 

*The “Other” closure reason category represents disputes that were 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.

As of November 30, 2025

From October 2025 to November 2025, both initiations and closures declined, partly due to two Federal holidays in November. 

In November 2025, 207,545 disputes were initiated, a decrease of 15% from October 2025 (243,784). Certified IDR entities closed 208,249 disputes in November 2025, 12% less than October 2025 (235,524). The number of dispute closures (443,773) was nearly equal to the number of initiations (451,329) in this two-month period, as certified IDR entities have closed much of the remaining IDR backlog.  

 

Table 1: Disputes Initiated

Number of Disputes Initiated, October 1, 2025 – November 30, 2025 

Number of Disputes Initiated, January 1, 2025 – November 30, 2025 

Number of Disputes Initiated, April 15, 2022 – November 30, 2025 

451,329 

2,291,586 

4,634,956 

 

Table 2: Reasons for Closure of Disputes

Closure Reason 

Number of Disputes Closed, 

October 1, 2025 – November 30, 2025 

Number of Disputes Closed, 

January 1, 2025 – November 30, 2025 

Number of Disputes Closed, 

April 15, 2022 – November 30, 2025 

Payment Determination 

346,343 

2,028,741 

3,299,465 

Found Ineligible 

88,200 

451,162 

803,482 

Other* 

9,230 

66,231 

174,609 

Total Closed Disputes 

443,773 

2,546,134 

4,277,556 

*The “Other” closure reason category represents disputes that were 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.

Fact Sheets

The fact sheet below provides additional information and context on Federal IDR operations.

Page Last Modified:
12/19/2025 10:20 AM
Help with File Formats and Plug-Ins