Skip to content
ABOUT CIDRE

Understanding the Federal IDR Process

The IDR process is a federal framework established under the No Surprises Act to resolve payment disputes between healthcare providers and health plans - protecting patients from unexpected medical bills through independent, neutral arbitration.

"By working with the IDR community, we strengthen the broader goal of the No Surprises framework - shielding patients from unexpected medical bills while objectively maintaining a functional healthcare payment system."

CIDRE MISSION STATEMENT

2M+ Per Year

Disputes via IDR

70%

Eligible out-of-network claims settled without IDR

$0

Additional patient liability 

THE IDR PROCESS

How Independent Dispute Resolution Works

The IDR process is a federal mechanism established under the No Surprises Act to resolve payment disputes between healthcare providers and health plans for certain out-of-network services. The process ensures that patients are protected from unexpected medical bills while allowing providers and plans to reach a payment determination – either through negotiation, or if negotiations do not succeed, through an independent third party.

When a dispute arises, providers and health plans first enter a 30-business-day open negotiation period. An estimated 70% of eligible out-of-network claims get resolved by this stage. If no agreement is reached, however, either party may initiate the IDR process. A certified IDR entity — an independent and neutral organization authorized by CMS under federal statutory standards — reviews the information submitted by both parties and determines the appropriate payment amount based on factors also outlined in federal law. Importantly, patients are not involved in this process and are held harmless from additional costs beyond their in-network cost-sharing responsibilities.

Who Are the IDR Entities

Certified IDR entities operate under strict federal standards established by Congress and verified by the Centers for Medicare & Medicaid Services (CMS). To ensure objectivity and compliance with the No Surprises Act, we maintain rigorous protocols governing fiscal integrity, patient data confidentiality, and comprehensive conflict-of-interest screening for every case we adjudicate.

Open Negotiation

Providers and health plans enter a 30-business-day negotiation period to attempt to resolve the payment dispute on their own. By the end of this stage of the process, over 70% of the disputes are resolved.

IDR Initiation

If no agreement is reached, either party may initiate the federal IDR process by submitting the dispute through the Federal IDR portal.. The initiating party will select their preferred IDR entity. , The responding party has 3-business days to respond to the selected IDR entity. The responding party can agree to the selection or propose an alternative IDR entity. If the responding party remains silent, the initiating party's selection is automatically finalized. If the responding party objects and proposes an alternative IDR entity, and the parties fail to reach a mutual agreement within 3-business days, CMS will randomly select a certified IDR entity.

Baseball-Style Arbitration

Each party submits one offer. The certified IDR entity measures each offer against six specific statutory criteria set by Congress and selects the most appropriate offer - it cannot compromise between offers. The law also prohibits the IDR entity from considering Medicare, Medicaid, TriCare or CHIP rates, usual and customary rates, or rates that would have been billed if the No Surprises Act had not been enacted.

Determination Issued

The party whose offer best reflects the statutory criteria prevails at the amount of their offer. Patients remain fully protected and pay nothing beyond their in-network cost-sharing.

IDR IN PRACTICE

The Process Since Implementation

Since its implementation under the No Surprises Act, the IDR process has become a critical framework for resolving payment disputes between providers and health plans — while keeping patients entirely out of the process.

Millions of Claims Resolved

In 2025, approximately 2.5 million disputes between health insurers and out-of-network providers were submitted through the federal IDR process, reflecting its role as an active and accessible resolution pathway for all stakeholders. Typically, 7.5-8 million out-of-network claims billed each year are eligible for the process – yet only 30% of them require the formal dispute resolution process to resolve, suggesting that the current size of the IDR program is in line with historic expectations.

Patients Fully Protected

Patients are not responsible for any disputed amounts beyond their in-network cost-sharing obligations and are not involved in the dispute process at all. The NSA has successfully prevented surprise bills for all covered services since 2022. 

70% Settled Without IDR

The insurance industry estimates that in 2024 there were tens of millions of out-of-network claims, of which an estimated  8.5 million were eligible for the IDR process.  Approximately 70% were resolved by plans and providers without any third-party IDR assistance. 

Cost-Effective Resolution

Compared to traditional dispute mechanisms such as litigation or arbitration, the IDR process is highly cost-effective — typically less than $800 per dispute, saving money for all stakeholders including consumers, and keeping litigation costs down for insurers.

Continuous Improvement

Compared to traditional dispute mechanisms such as litigation or arbitration, the IDR process is highly cost-effective — typically less than $800 per dispute, saving money for all stakeholders including consumers, and keeping litigation costs down for insurers.

CIDRE'S MISSION

Committed to a Balanced, Independent IDR Process

CIDRE advocates for evidence-based, independent, and balanced policies that protect the integrity of the processes meant to shield patients from surprise medical billing. We educate lawmakers, regulators, and stakeholders on the operational realities and public value of the IDR system.

Regulatory Stability & Clarity

Promoting regulatory clarity that allows IDR entities to operate efficiently and impartially, with consistent rules that all parties can rely on. 

Process Independence

Defending the independence of the dispute resolution process from undue influence, ensuring certified entities can make impartial decisions on the merits of each case. 

Evidence-Based Policy

Supporting evidence-based policymaking that maintains an objective balance between providers, payers, and patients — consistent with the Congressional design of the No Surprises Act.

Stakeholder Education

Informing lawmakers, regulators, and stakeholders on the operational realities and public value of the IDR system so that policy decisions are grounded in how the process actually works. 

A BALANCED FRAMEWORK

How the IDR Process Promotes Evidence-based Decisions

P
Providers and Health Plans
The submitting party provides an offer that is measured against statutory criteria set by Congress. Since the No Surprises Act was enacted, provider in-network participation rates have actually increased — from 90% to 93% — demonstrating that the IDR process supports, rather than disrupts, the in-network system.
H
Responding Party
The responding party then submits its own offer, and the IDR entity selects the offer that best represents the value of the item or service. The structure encourages reasonable, good-faith offers from all parties and supports consistency and transparency in how disputes are resolved.
Pt
Patients
Patients are entirely insulated from the dispute process. They pay only their in-network cost-sharing amounts and bear no responsibility for any disputed amounts. The No Surprises Act has successfully protected Americans from surprise medical bills for all covered services since its enactment.

Get In Touch

Questions about CIDRE’s work or membership?
We’d love to hear from you..
Mary Jane Rodes, Association Manager

maryjane@rodesconsulting.com

2020 Pennsylvania Ave NW, Suite 511
Washington, DC 20006