As providers close the books on IDR results for 2025 and focus on the year ahead, one question remains: What do recent federal Independent Dispute Resolution (IDR) outcomes suggest about reimbursement dynamics for 2026?
Year-end IDR results from the No Surprises Act (NSA) Independent Dispute Resolution Process Data Analysis for 2024 were released towards the end of 2025. They offer a clear snapshot of how providers, payers, and arbitrators interact under the statute. Highlights of the report include:
- 2024 marking the first full year the federal IDR process operated without suspension.
- Providers’ median offers exceeding the qualifying payment amount (QPA) in several hospital-based specialties.
- IDR volume and the number of payment determinations continuing to increase as the process matured.
This analysis highlights specialty-level patterns to help you benchmark expectations as IDR activity continues into 2026.
How IDR Payment Determinations Are Made (QPA, Factors, and Limits)
Under the federal IDR framework, arbitrators must select one of the two submitted payment offers, either from the provider or the payer. The No Surprises Act requires the IDR arbitrator to base this decision on statutory criteria, rather than splitting the difference. The arbitrator must consider the qualifying payment amount (QPA), defined as the plan’s median in-network rate for the same service in the same geographic area, and other credible information submitted by the parties when determining which offer reflects the appropriate out-of-network payment amount Other factors that may be considered when supported by credible documentation include patient acuity, your experience, market share, good faith efforts to reach an in-network agreement, and the complexity of the service you provided. While arbitrators have some flexibility in the determination based on the other factors, the law prohibits arbitrators from considering the following factors:
- Billed charges
- Usual and customary rates
- Medicare and Medicaid payment levels
The NSA IDR process data report shows that arbitrator decisions reflect a balanced approach to decision-making, instead of defaulting to QPA alone.
2025 IDR Results by Medical Specialty: System-Wide Trends
Federal IDR data shows the majority of disputes stem from hospital-based specialties, reflecting clinical settings where patients typically have limited ability to choose in-network providers. These specialties include:
- Emergency medicine
- Anesthesiology
- Radiology
- Pathology
- Air ambulance services
Because of this concentration, these specialties remain central to the federal IDR framework. In many cases, prevailing payment offers selected by arbitrators exceed the QPA, though outcomes vary by service type, documentation, and payer behavior.
An analysis of the CMS federal IDR determination data shows that the relationship between prevailing offers and the QPA is not uniform across specialties or over time. The report also highlights an increase in outcome variability, rather than settling for averages. From 2022 to 2024, the variances between QPA and other factors indicate that arbitrators consider multiple factors in their final determinations.
The CMS report reveals a 2025 IDR results trend: payer behavior isn’t rigid, and there are larger spreads between submitted offers in certain disputes. Taken together, these patterns help explain why IDR remains relevant for providers seeking fair reimbursement and clearer insight into how payments are determined under the federal framework. Providers want to know what affects their payments and how these effects differ by specialty, payer, and market under the federal IDR framework.
Where Outcomes Differ by Specialty
Federal IDR outcomes vary by specialty, shaped by differences in clinical context, dispute volume, and how statutory factors are presented. Analysis of the CMS federal IDR determinations and Congressional Research Service reporting highlights several consistent directional patterns across NSA-eligible specialties.
Emergency Medicine
Emergency medicine accounts for a significant share of federal IDR disputes due to unavoidable out-of-network encounters. The CRS analysis shows that prevailing offers often exceed the QPA, with moderate variability across determinations.
The difference might indicate sensitivity to case-specific factors, plus the differences in payor behavior are evident. There are wider spreads between submitted offers in some disputes, pointing to variability across plans rather than across providers alone, cementing the payor variance 2025 IDR results trend.
Anesthesiology
Anesthesiology disputes tend to demonstrate more consistent outcomes compared to other hospital-based specialties, according to the CRS report. Prevailing offers typically exceed the QPA by a narrower range, with less volatility over time.
Radiology
Radiology outcomes under IDR show greater diffusion across different service types and markets. The CRS time-series analysis highlights increasing divergence between selected offers and the QPA in certain categories, suggesting greater weighting of non-QPA factors in some cases.
Pathology
Pathology disputes represent a smaller overall share of IDR volume but exhibit notable outcome variability. Federal reporting shows that while prevailing offers often exceed the QPA, results are less predictable than in anesthesiology or emergency medicine.
Air Ambulance
Air ambulance disputes stand out for both higher prevailing offers relative to the QPA and greater volatility across determinations. Federal data shows wide gaps between submitted offers, reflecting unique cost structures and limited in-network contracting options. CMS data also shows significant payer-to-payer variation, reinforcing that outcomes in this specialty are particularly sensitive to payer posture and dispute strategy rather than a single benchmark.
What 2025 IDR Results Mean for Provider Strategy in 2026
2025 IDR results underscore that outcomes vary by payer, market, and specialty. Rather than pursuing every eligible dispute, providers may benefit from a selective, data-informed approach in 2026.
IDR data can also support smarter prioritization by highlighting where outcomes have historically been more consistent, while reinforcing that individual results depend on case-specific factors.
Common Misinterpretations of 2025 IDR Results Data
Federal IDR data is most valuable when used in the proper context. Interpreting it helps providers set clearer expectations and apply insights better:
- IDR data highlights trends, not guarantees: Federal reports reflect historical determinations across many cases. Eligibility, documentation quality, and the presentation of statutory factors in each dispute shape individual outcomes.
- CMS averages offer context, not predictions: Because CMS data aggregates results across specialties, payers, and markets, averages are best used as directional benchmarks rather than forecasts for any single claim.
- Dispute volume and outcomes measure different things: Higher IDR volume signals where disputes occur, while outcomes reflect how they resolve those disputes. Evaluating both together provides a more complete picture of IDR performance.
Used appropriately, IDR insights help providers identify patterns and make more informed decisions without relying on assumptions based on individual claims.
Turning IDR Results Into Smarter Decisions
As 2025 IDR results data continues to mature, its value lies in helping providers move beyond averages and approach disputes with clearer expectations. Understanding how payment determinations are made allows providers to allocate resources more intentionally and view IDR as part of a broader reimbursement strategy.
In 2026, success will be more about insight and knowing when to use IDR. With experienced support and reliable data, providers can navigate the federal IDR process with greater clarity and sustainability. Contact Pivotal Health today to learn how informed use of IDR data can support fair reimbursement decisions in the year ahead.
Sources
https://www.congress.gov/crs-product/R48738
https://www.cms.gov/nosurprises/policies-and-resources/reports
https://www.cms.gov/files/document/federal-idr-puf-general-information.pdf
