Part of the Medical bills playbook.
Surprise-billing arbitration filings doubled in 2025 — and the federal fee to file has dropped from $115 to $15
Providers and health plans filed 1.2 million new disputes in the No Surprises Act's federal arbitration system in the first half of 2025 — more than double the same period in 2024, in a process federal officials once expected to handle about 17,000 disputes a year. Separately, for disputes started on or after June 11, 2026, the federal administrative fee dropped from $115 to $15 per party.
What this means for you
The No Surprises Act was written to keep patients out of the middle of billing fights between out-of-network providers and insurers — and that patient protection applies no matter how backed up the arbitration machine gets. What the volume shows is how rarely the two sides agree on their own, even with a formal referee. Consumers dealing with a medical bill dispute are often facing the same billing departments and insurers that generate these millions of cases, and the pattern across this data is consistent: disagreements this common get resolved on records, not on phone calls.
The facts
- Parties submitted 1.2 million new disputes to the federal IDR portal in the first six months of 2025 — more than double the roughly 590,000 filed in the first two quarters of 2024.per CMS federal IDR data, as analyzed by Georgetown University's Center on Health Insurance Reforms · as of March 30, 2026
- Federal officials originally projected approximately 17,000 IDR disputes per year when the process was created.per the October 2021 federal interim final rule on surprise billing · as of October 7, 2021
- IDR administrative and arbitrator fees totaled $844 million in the first half of 2025 — nearly as much as the $885 million charged from 2022 through 2024 combined.per Georgetown CHIR's analysis of CMS IDR reports · as of March 30, 2026
- For disputes initiated on or after June 11, 2026, the federal IDR administrative fee is $15 per party per dispute, down from $115.per the CMS Federal Independent Dispute Resolution Operations final rule · as of June 11, 2026
What you can do
Keeping every bill, explanation of benefits, and letter — with dates — is what makes a billing dispute concrete later. Comparing a bill against the insurer's explanation of benefits line by line often surfaces the exact disagreement. Noting the date on every notice matters, because most formal dispute channels run on windows that open and close.
Common questions
What is the No Surprises Act's IDR process?
Independent dispute resolution (IDR) is the federal arbitration process where out-of-network providers and health plans resolve payment disagreements without billing the patient for the difference. A certified independent arbitrator reviews both sides' offers and picks one.
Does the surprise-billing arbitration backlog change what patients owe?
No. Under the No Surprises Act, patient cost-sharing for covered surprise bills is calculated as if the care were in-network, regardless of how long the provider-insurer arbitration takes. The disputes in the IDR system are between providers and health plans.