Independent Dispute Resolution Reports
The No Surprises Act (NSA) and its implementing regulations established a Federal Independent Dispute Resolution (IDR) process that out-of-network (OON) providers, facilities, and providers of air ambulance services, and group health plans, health insurance issuers in the group and individual markets, and Federal Employees Health Benefits (FEHB) Program carriers (collectively, the disputing parties) may use to determine the OON rate for qualified IDR items or services after an unsuccessful open negotiation period.
The Departments of Health and Human Services, Labor, and the Treasury (the Departments) launched the Federal IDR portal on April 15, 2022, to facilitate this process. The statute requires the Departments to publish on a public website certain information about the Federal IDR process. To promote transparency in the implementation of the Federal IDR portal, the Departments are sharing the below data with the public.
Federal IDR public use files (PUF)
For more information about the Federal IDR Public Use Files (PUF), please review the below documentation that was updated on January 21, 2026:
- Federal IDR PUF General Information (PDF)
- Federal IDR Supplemental Tables General Information (PDF)
- Federal IDR PUF Data Dictionary (XLSX)
- Federal IDR PUF Data Disclaimer—User Agreement (PDF)
- 2025 Reporting Year
- Federal IDR PUF for 2025 Q1 (as of January 21, 2026) (ZIP)
- Federal IDR PUF for 2025 Q2 (as of January 21, 2026) (ZIP)
- Federal IDR Supplemental Tables for 2025 Q1 (as of January 21, 2026) (XLSX)
- Federal IDR Supplemental Tables for 2025 Q2 (as of January 21, 2026) (XLSX)
- Supplemental Background on the Federal IDR PUF, January 1, 2025 - June 30, 2025 (as of January 21, 2026) (PDF)
- 2024 Reporting Year
- Federal IDR PUF for 2024 Q1 (as of March 18, 2025) (XLSX)
- Federal IDR PUF for 2024 Q2 (as of March 18, 2025) (XLSX)
- Federal IDR PUF for 2024 Q3 (as of May 28, 2025) (XLSX)
- Federal IDR PUF for 2024 Q4 (as of May 28, 2025) (XLSX)
- Federal IDR Supplemental Tables for 2024 Q1 (as of March 18, 2025) (XLSX)
- Federal IDR Supplemental Tables for 2024 Q2 (as of March 18, 2025) (XLSX)
- Federal IDR Supplemental Tables for 2024 Q3 (as of May 28, 2025) (XLSX)
- Federal IDR Supplemental Tables for 2024 Q4 (as of May 28, 2025) (XLSX)
- Supplemental Background on the Federal IDR PUF, January 1 - June 30, 2024 (as of March 18, 2025) (PDF)
- Supplemental Background on the Federal IDR PUF, July 1 - December 31, 2024 (as of May 28, 2025) (PDF)
- 2023 Reporting Year
- Federal IDR PUF for 2023 Q1 (as of February 15, 2024) (XLSX)
- Federal IDR PUF for 2023 Q2 (as of February 15, 2024) (XLSX)
- Federal IDR PUF for 2023 Q3 (as of June 13, 2024) (XLSX)
- Federal IDR PUF for 2023 Q4 (as of June 13, 2024) (XLSX)
- Federal IDR Supplemental Tables for 2023 Q1 (as of February 15, 2024) (XLSX)
- Federal IDR Supplemental Tables for 2023 Q2 (as of February 15, 2024) (XLSX)
- Federal IDR Supplemental Tables for 2023 Q3 (as of June 13, 2024) (XLSX)
- Federal IDR Supplemental Tables for 2023 Q4 (as of June 13, 2024) (XLSX)
- Supplemental Background on the Federal IDR PUF, January 1 - June 30, 2023 (as of February 15, 2024) (PDF)
- Supplemental Background on the Federal IDR PUF, July 1 - December 31, 2023 (as of June 13, 2024) (PDF)
- Federal Independent Dispute Resolution Process—Status Update (April 27, 2023) (PDF)
- 2022 Reporting Year
Federal IDR bi-monthly reports
To provide transparency into the operations of the Federal IDR process, the Departments are releasing information to the public bi-monthly in addition to the quarterly PUF release schedule. This bi-monthly update is not intended to be a substitute for the more comprehensive release of IDR information in the IDR PUFs and Federal IDR Supplemental Tables released by the Departments as required under the statute.
As noted previously in the September 2025 Fact Sheet (Fact Sheet: Clearing the Independent Dispute Resolution Backlog (PDF)), certified IDR entities closed much of the outstanding dispute backlog over the course of 2025 and are now closing disputes at a pace that keeps up with new dispute initiations.
- As of January 31, 2026
In January 2026, dispute initiations (248,452) declined by 7% from December 2025 (267,789).
Certified IDR entities closed 257,724 disputes in January 2026, a 4% increase over December 2025 (248,518). From December 1, 2025 – January 31, 2026, dispute closures (506,242) were nearly equal to dispute initiations (516,241), as certified IDR entities have previously closed much of the remaining IDR backlog.
Table 1: Disputes Initiated
Number of Disputes Initiated,
December 1, 2025 – January 31, 2026
Number of Disputes Initiated,
January 1, 2026 – January 31, 2026
Number of Disputes Initiated,
April 15, 2022 – January 31, 2026
516,241
248,452
5,151,197
Table 2: Reasons for Closure of Disputes
Closure Reason
Number of Disputes Closed,
December 1, 2025 – January 31, 2026
Number of Disputes Closed,
January 1, 2026 – January 31, 2026
Number of Disputes Closed,
April 15, 2022 – January 31, 2026
Payment Determination
399,338
203,543
3,696,802
Found Ineligible
97,074
49,196
899,309
Other*
9,830
4,985
184,366
Total Closed Disputes
506,242
257,724
4,780,477
*The “Other” closure reason category represents disputes that were either withdrawn by disputing parties, closed due to an outside settlement between the disputing parties, or closed for administrative reasons, such as data entry errors or the failure of both parties to pay fees or submit offers.
- As of November 30, 2025
From October 2025 to November 2025, both initiations and closures declined, partly due to two Federal holidays in November.
In November 2025, 207,545 disputes were initiated, a decrease of 15% from October 2025 (243,784). Certified IDR entities closed 208,249 disputes in November 2025, 12% less than October 2025 (235,524). The number of dispute closures (443,773) was nearly equal to the number of initiations (451,329) in this two-month period, as certified IDR entities have closed much of the remaining IDR backlog.
Table 1: Disputes Initiated
Number of Disputes Initiated, October 1, 2025 – November 30, 2025
Number of Disputes Initiated, January 1, 2025 – November 30, 2025
Number of Disputes Initiated, April 15, 2022 – November 30, 2025
451,329
2,291,586
4,634,956
Table 2: Reasons for Closure of Disputes
Closure Reason
Number of Disputes Closed,
October 1, 2025 – November 30, 2025
Number of Disputes Closed,
January 1, 2025 – November 30, 2025
Number of Disputes Closed,
April 15, 2022 – November 30, 2025
Payment Determination
346,343
2,028,741
3,299,465
Found Ineligible
88,200
451,162
803,482
Other*
9,230
66,231
174,609
Total Closed Disputes
443,773
2,546,134
4,277,556
*The “Other” closure reason category represents disputes that were withdrawn by disputing parties, closed due to outside settlement between the disputing parties, or were closed for administrative reasons, such as data entry errors or the failure of both parties to pay fees or submit offers.
- As of September 30, 2025
In September 2025, 219,234 disputes were initiated, a decrease of 1% over August 2025 (220,626).
From August 2025 to September 2025, both initiations and closures declined slightly, but the number of dispute closures continued to exceed initiations, as certified IDR entities worked to clear the remaining IDR backlog. Certified IDR entities closed 240,579 disputes in September 2025, 10% more than were initiated in September 2025 (219,234), and 6% less than were closed in August 2025 (256,542).
Table 1: Disputes Initiated
Number of Disputes Initiated, August 1, 2025 – September 30, 2025
Number of Disputes Initiated, January 1, 2025 – September 30, 2025
Number of Disputes Initiated, April 15, 2022 – September 30, 2025
439,860
1,840,257
4,183,627
Table 2: Reasons for Closure of Disputes
Closure Reason
Number of Disputes Closed, August 1, 2025 – September 30, 2025
Number of Disputes Closed, January 1, 2025 – September 30, 2025
Number of Disputes Closed, April 15, 2022 – September 30, 2025
Payment Determination
393,830
1,684,567
2,955,772
Found Ineligible
89,257
365,629
718,396
Other*
14,034
57,112
165,514
Total Closed Disputes
497,121
2,107,308
3,839,682
*The “Other” closure reason category represents disputes that were withdrawn by disputing parties, closed due to outside settlement between the disputing parties, or were closed for administrative reasons, such as data entry errors or the failure of both parties to pay fees or submit offers.
- As of July 31, 2025
In July 2025, 213,585 disputes were initiated, an increase of 4% over June 2025 (206,131).
The Federal IDR program dispute closure volume continues to rise month over month. Certified IDR entities closed 263,350 disputes in July 2025, 4% more than June 2025 (252,422) and 23% more than were initiated in July 2025 (213,585).
Table 1: Disputes Initiated
Number of Disputes Initiated, June 1, 2025 – July 31, 2025 Number of Disputes Initiated, Jan 1, 2025 – July 31, 2025 Number of Disputes Initiated, April 15, 2022 – July 31, 2025 419,716
1,400,397
3,743,767
Table 2: Reasons for Closure of Disputes
Closure Reason Number of Disputes Closed, June 1, 2025 – July 31, 2025 Number of Disputes Closed, Jan 1, 2025 – July 31, 2025 Number of Disputes Closed, April 15, 2022 – July 31, 2025 Payment Determination 412,476
1,291,236
2,562,612
Found Ineligible 91,684
277,403
630,428
Other* 11,612
43,150
151,576
Total Closed Disputes 515,772
1,611,789
3,344,616
*The “Other” closure reason category represents disputes that were withdrawn by disputing parties, closed due to outside settlement between the disputing parties, or were closed for administrative reasons, such as data entry errors or the failure of both parties to pay fees or submit offers.
- As of May 31, 2025
In May 2025, 209,637 disputes were initiated, a decrease of 7% over April 2025 (225,622).
The Federal IDR program dispute closure volume continues to rise month over month. Certified IDR entities closed 264,805 disputes in May 2025, 8% more than April 2025 (244,705) and 26% more than were initiated in May (209,637).
Table 1: Disputes Initiated
Number of Disputes Initiated, April 1, 2025 – May 31, 2025 Number of Disputes Initiated, January 1, 2025 – May 31, 2025 Number of Disputes Initiated, April 15, 2022 – May 31, 2025 435,259
980,681
3,324,051
Table 2: Reasons for Closure of Disputes
Closure Reason Number of Disputes Closed, April 1, 2025 – May 31, 2025 Number of Disputes Closed, January 1, 2025 – May 31, 2025 Number of Disputes Closed, April 15, 2022 – May 31, 2025 Payment Determination 413,466
879,879
2,152,045
Found Ineligible 82,976
186,286
539,664
Other* 13,068
31,605
140,095
Total Closed Disputes 509,510
1,097,770
2,831,804
* The “Other” closure reason category represents disputes that were withdrawn by disputing parties, closed due to outside settlement between the disputing parties, or were closed for administrative reasons, such as data entry errors or the failure of both parties to pay fees or submit offers.
Fact Sheets
The fact sheet below provides additional information and context on Federal IDR operations.