The Departments of Health and Human Services, Labor, and the Treasury (Departments) recently released the Federal Independent Dispute Resolution (IDR) public use files (PUF) and supplemental tables for the third and fourth quarters of 2025, and the numbers should get the attention of every plan sponsor and fiduciary overseeing a self-insured group health plan. The data confirms two trends: the No Surprises Act’s IDR process is becoming more efficient for providers, and it continues to produce outcomes that skew heavily against payers. As discussed in a previous post, these dynamics are already contributing to rising health plan costs, and the latest data only reinforces that trend.

Dispute Volume Continues to Climb, and Self-Insured Plans Are the Primary Target

Between July 1 and December 31, 2025, disputing parties initiated 1,372,563 disputes through the Federal IDR portal, a 16% increase over the first half of 2025. Just ten initiating parties, many of them large practice management or revenue cycle management companies, accounted for roughly 66% of all disputes. HaloMD, Team Health, and SCP Health alone represented approximately 38% of all disputes initiated in the period.

Critically, the PUF data shows that self-insured plans are disproportionately exposed. In the second half of 2025, self-insured employer group health plans were the named non-initiating party in roughly 68% of the disputes. By contrast, fully insured group health plans, individual market issuers, and FEHB carriers each represented a much smaller share.

Providers Are Winning the Vast Majority of Payment Determinations

The outcome data continues to favor providers, facilities, and air ambulance providers. Nationally, providers prevailed in approximately 85% of payment determinations in the last half of 2025. This is a slight decrease from the 88% prevailing rate in the first half of 2025. However, because nearly 300,000 more disputes were filed in the second half of the year, payers actually experienced more losses in absolute terms during that period.

Significantly for plan cost projections, the prevailing offer exceeded the Qualifying Payment Amount (QPA) in approximately 87% of payment determinations in the last six months of 2025. The QPA is the median in-network rate for the specific item or service in the relevant geographic area. Many plans and issuers tend to anchor their initial payment amounts and IDR offers to the QPA, even though this negotiating posture has not prevented above-QPA awards in the vast majority of cases.

The Financial Stakes Are Rising by Specialty

The specialty-level data shows where self-insured plans face the greatest financial exposure. Emergency department services made up the largest share of all payment determinations: 52% for the full six-month period, and over 300,000 determinations each quarter. Radiology accounted for another 15% of determinations for the period. Certain lower-volume specialties carried outsized award premiums relative to QPA: in Q3 2025, median prevailing neurology and neuromuscular procedures offers were 2,394% of QPA, and median prevailing gastroenterology offers reached 6,780% of QPA.

The Process Is Getting Faster, Which Means Faster Financial Exposure

Plans can no longer count on IDR backlogs to delay resolution and cash outflows. As of the end of 2025, 98% of all disputes submitted since the program began in April 2022 were either resolved or less than 30 business days old. The Departments certified two additional IDR entities (Capitol Bridge, LLC and Livanta, LLC) in June 2025, raising the total from 13 to 15, and these entities began processing disputes in September 2025. A third IDR entity (Dane Street, LLC), was added in early 2026. Although outside the timing of the PUF data, this addition will likely reduce delays even further. For self-insured plans, this means disputes are resolving into binding payment obligations more quickly than in prior years.

Administrative Fees and Certified IDR Entity Fees Are Substantial

Self-insured plans should also budget for the collateral costs of the IDR process itself. In the last half of 2025, administrative fees collected totaled approximately $283 million and certified IDR entity fees totaled approximately $649 million. Although the May 2026 final IDR Operations Rule (discussed here) decreased the administrative fee amount from $115 to $15 per party, per dispute, the Departments estimated that the reduction could lead to a 30% increase in disputes filed. For group health plans and other payers, the lower per-dispute fee may reduce administrative costs on a per-case basis, but the resulting increase in dispute volume could raise total IDR-related costs overall.

Thompson Hine Takeaways for Self-Insured Group Health Plans

• Request TPA reporting. Plans should ask their TPAs for plan-specific IDR reporting, not just aggregate carrier-level statistics.This data can reveal plan-specific risks tied to the IDR process that aggregate statistics obscure.
• Ensure network adequacy. Plans should scrutinize network adequacy in high-exposure specialties such as emergency medicine, radiology, and neurology, where award premiums over QPA are most severe. Fewer out-of-network services can translate to lower IDR costs.
• Understand IDR timelines for future claims predictions. Given the shrinking dispute-resolution timeline, plans should build IDR outcomes into ongoing claims and stop-loss forecasting rather than treating them as rare, one-off events.
• Discuss network and contracting strategies with the TPA. Because a small number of provider groups and practice management companies are driving the majority of disputes, plans facing repeat filers should consider whether targeted network or contracting strategies could reduce future exposure.

The overall picture from the Q3 and Q4 2025 PUF data is one of a maturing, faster, and increasingly provider-favorable federal IDR process. Self-insured group health plans can no longer treat the IDR process as background regulatory noise, but should consider it a direct and growing cost driver of group health plan costs.