New Study Shows No Surprises Act IDR Program Protects Patients From Costly Surprise Medical Bills

July 24, 2026 – The Coalition for Independent Dispute Resolution Entities (CIDRE) has commissioned an analysis of the federal independent dispute resolution (IDR) program created by the No Surprises Act to inform policymaking. Prepared by Charm Economics, Inc., its conclusions are:

• The original goal of the No Surprises Act, protecting patients from surprise medical bills, has been achieved, and the IDREs are performing their role in ensuring the statutory dispute resolution process is working transparently.
• Historic out-of-network claims rates suggest that the current size of the IDRE program is in line with expectations; preliminary federal estimates of annual filings of 17-22,000 were flawed, not an indication of any misuse of the IDR process.
• The high provider win rate in the initial years of the IDR program is partially attributable to provider administrative compliance rates; 26% of disputes were resolved through a default decision when only one party participated, with plans defaulting 90% of those cases. With greater rates of participation from both parties, the win rate is expected to level out.
• The program has not caused providers to leave networks in pursuit of arbitration awards, and in-network claim rates actually rose since implementation of the program for 75% of affected specialties.
• The vast majority of ineligible claims fail due to complex procedural or jurisdictional rules—such as falling under state law instead of federal law, missing strict timing windows, or improper claim grouping—rather than bad-faith gaming by the parties to the process.

The Centers for Medicare & Medicaid Services recently released a Final Rule improving the IDR program, and CIDRE supports further rulemaking as the appropriate method for adjusting a bipartisan law with high public support.

“CIDRE’s comprehensive analysis of the No Surprises Act shows the IDR process is working as it was designed by Congress. The program serves to protect patients from receiving unaffordable surprise medical bills and to fairly and timely resolve disputes between providers and plans. The system will continue improving as all parties learn and adjust their approaches. CIDRE’s members are leading efforts to protect patients as the IDR entities charged with resolving these disputes,” said David Farber, counsel to CIDRE.

CIDRE (Coalition for Independent Dispute Resolution Entities) advocates for fair, transparent, 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.