Providers won 85% of federal No Surprises Act payment disputes in 2025, according to Georgetown University's Center on Health Insurance Reforms (CHIR). The median award was 445% of the qualifying payment amount (QPA), the benchmark based on a plan's median in-network rate for the same service.
The numbers below come from federal dispute data and the analyses built on it. They cover win rates, award sizes, volume, speed and the 2026 fee change.
How often providers win
CHIR's March 2026 analysis of the first half of 2025 found providers won 88% of disputes. The same analysis put the 2024 win rate at 85% and the 2023 rate at 81%. For the second half of 2025, HFMA reported an 85% provider win rate across 1.15 million determinations, citing the Departments of Labor, Treasury and Health and Human Services.
Awards usually landed above the benchmark. HFMA reported that 87% of second-half 2025 determinations exceeded the QPA. CHIR's August 2026 analysis found that plans, when they won, received a median award of 105% of the QPA.
Results differ by arbitrator. CHIR measured a 99.4% provider win rate at one certified IDR entity in the fourth quarter of 2025 and 54.5% at another. State processes also differ. In Virginia, between May 2024 and May 2025, providers won 45% of 252 state cases, against 85% in federal disputes in 2024, per CHIR.
What awards look like by specialty
CHIR's August 2026 analysis found a median award of 445% of the QPA across 2025 disputes. At the 90th percentile, awards reached 1,771% of the QPA. HFMA's July 2026 report gives median awards by specialty for the last two quarters of 2025.
| Specialty | Q3 2025 median award (% of QPA) | Q4 2025 median award (% of QPA) | Second-half 2025 decisions |
|---|---|---|---|
| Emergency services | 324% | 334% | 633,000 |
| Surgery | 1,449% | 1,503% | about 1,900 |
| Neurology | 2,394% | 2,585% | more than 66,000 |
Source: HFMA, "New data on No Surprises Act IDR cases show providers won often in 2025," July 27, 2026, from federal supplemental tables.
The mix of disputes is heavily weighted toward two specialties. HFMA reported emergency services made up 52% of second-half 2025 disputes and radiology 15%. CHIR measured resolved dispute lines for all of 2025 and found emergency medicine at 41%, radiology at 29%, surgery at 5% and neurology at 5%. Surgery awards totaled $3.8 billion and neurology awards $2 billion in CHIR's count.
Volume and speed
CHIR counted 1.2 million new disputes in the first half of 2025, double the 590,000 filed in the first half of 2024. HFMA reported 1.37 million filings in the second half of 2025, up 16% from the first half. CHIR put the 2025 total at 2.6 million new disputes, a 77% increase over 2024. The federal government had expected about 22,000 disputes a year.
Processing sped up. In the first half of 2025, two-thirds of determinations missed the 30-day requirement, per CHIR. In the second half, 62% of determinations came within 30 days, against 37% in the first half, per HFMA. CHIR reported a median resolution time of 25 days in the fourth quarter of 2025.
Eligibility fights became less likely to succeed. Payers challenged 42% of second-half disputes as ineligible, per HFMA. Arbitrators ruled 19% of disputes ineligible in the second half of 2025, against 69% in the first half of 2022. CHIR counted default decisions in 22% of first-half 2025 disputes.
Who files, and what that means for the averages
CHIR found providers started 99.9% of disputes in the first half of 2025. Within provider filings, 80% came from clinicians and 20% from facilities. HFMA's second-half figures were 76% clinician and 24% facility.
A few filers account for most of the volume. In the first half of 2025, the top four initiators filed 56% of all disputes, per CHIR. For all of 2025, CHIR found three filers made up 77% of resolved dispute lines. The win rates above therefore describe large, high-volume dispute operations. A small practice filing a handful of claims a year has no published win rate of its own.
The disputes target a concentrated group of payers as well. In the first half of 2025, the top three payers accounted for 57% of cases, per CHIR. Texas alone had 524,630 disputes initiated in the second half of 2025, per HFMA.
What a dispute costs to file in 2026
A May 2026 final rule cut the per-party federal administrative fee from $115 to $15 per dispute. HFMA reported the rule on May 28, 2026, and Jones Day reported the fee applies to disputes initiated on or after June 11, 2026.
| Item | Before | After the 2026 rule |
|---|---|---|
| Federal administrative fee, per party | $115 | $15 |
| Maximum line items in one batched dispute | 25 | 50 |
Sources: HFMA, "No Surprises Act IDR rule," May 28, 2026; Jones Day, "New Rule Amends No Surprises Act Dispute Process," June 8, 2026.
The rule also gives the other party 3 business days to respond to a notice of initiation and the arbitrator 5 business days after assignment to decide eligibility, per Jones Day. The administrative fee is one part of the cost. A separate fee goes to the certified IDR entity. The December 2023 fee rule set ranges of $200 to $840 for a single determination and $268 to $1,173 for a batched determination, plus $75 to $250 for each added block of 25 items beyond the first 25, per NFP's summary.
System-wide, CHIR counted $844 million in IDR fees in the first half of 2025, against $885 million for all of 2022 through 2024. For 2022 through 2025, CHIR estimated $2.7 billion in IDR administrative and entity fees and $4.2 billion in internal administrative costs.
The 30-day open negotiation window now starts only after a formal submission through the IDR portal. A new IDR Gateway platform is due later in 2026, per Jones Day.
Sources
- Georgetown University CHIR, The No Surprises Act IDR Process: An Early Look At 2025 Data, March 30, 2026
- Georgetown University CHIR, Spending On IDR Process Pushes No Surprises Act Costs To More Than $22.4 Billion Over Just Four Years, August 26, 2026
- HFMA, New data on No Surprises Act IDR cases show providers won often in 2025, July 27, 2026
- HFMA, No Surprises Act IDR rule, May 28, 2026
- Jones Day, New Rule Amends No Surprises Act Dispute Process for Out-of-Network Health Care Payments, June 8, 2026
- NFP, Federal IDR Process Administrative Fee and Certified IDR Entity Fee Ranges Final Rule, December 21, 2023
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