What 2025 Tells Us About Federal IDR in 2026 and Beyond

We now have the first complete view of 2025 from the latest Federal Independent Dispute Resolution Public Use Files, even as the Federal IDR market has already moved well beyond where it stood at year-end.

The Q3 and Q4 data is particularly useful for providing insight into where Federal IDR was heading as it entered 2026: dispute volume continues to grow rapidly. IDR entities are processing that volume more efficiently. CMS is providing richer data about dispute outcomes. And, as the mechanics of processing disputes improve, provider organizations have a growing opportunity to apply better strategy to an increasingly large inventory of potential disputes.

In other words, 2026 and beyond will increasingly be about strategy, prioritization, and automation.

Federal IDR has entered a new level of scale

Disputing parties initiated approximately 2.56 million Federal IDR disputes during 2025, with growth accelerating during the year: approximately 1.19m disputes filed during the first six months and 1.37m during the second half of the year.

On top of that, early 2026 activity suggests that growth has continued; through May 31, CMS reports 1.43m+ disputes initiated, compared with roughly 980,000 during the same period in 2025.

That represents approximately 46% YOY growth in disputes. At the same time, processing capacity is improving amongst arbitrators:

• During the second half of 2025, certified IDR entities closed approximately 1.45 million disputes while 1.37 million were initiated, showing they are prepared for this continued growth.
• By year-end, CMS reported that 98% of all disputes submitted since the program began had either been resolved or were less than 30 business days old.

Timeliness improved as well: while only 37% of payment determinations were completed within 30 business days during the first half of 2025, that number increased to 62% during the second half.

All this means that dispute volumes are continuing to grow and arbitrators are focused on greater work process throughput to support that growth.

What could 2026 look like?

To quantify this growth, annualizing the 1.43 million disputes initiated through May would produce approximately 3.44 million disputes for 2026. If growth moderates and full-year volume finishes only approximately 25% above 2025, Federal IDR would approach 3.2 million disputes. If the approximately 46% year-over-year growth observed through May continues, volume could approach 3.7 million.

That suggests a reasonable planning range of roughly 3.2 million to 3.7 million disputes, with significant uncertainty around the final outcome. Several changes could influence that trajectory:

• Beginning June 11, 2026, the Federal IDR administrative fee dropped from $115 to $15 per party per dispute. That materially changes the economics of pursuing lower-dollar disputes and will very likely dramatically increase the population of claims for which IDR is economically viable.
• The phased rollout of the IDR Gateway, new batching requirements, and other provisions of the 2026 Federal IDR Operations final rule will likely influence submission behavior, albeit, it is far to early to tell what that influence might be.

In the end, everyone should prepare for a Federal IDR environment measured in millions of disputes annually.

Better data creates new opportunities for strategy

One of the most interesting changes in the Q3 and Q4 PUF release received relatively little attention. For the first time, CMS included the certified IDR entity associated with each dispute line item, creating a new analytical dimension for provider organizations.

Providers can now begin evaluating combinations such as:

IDR entity + payer + service code + specialty + geography + outcome + QPA

My review of the Q3 and Q4 data shows meaningful variation in outcomes across IDR entities, including within common high-volume service codes.

Those differences, however, do require careful interpretation. Payer mix, provider population, geography, dispute type, defaults, case complexity, and selection behavior can all influence results. A simple IDRE win-rate ranking would therefore provide limited strategic value.

The stronger opportunity is to identify how particular IDR entities have historically handled disputes that resemble the cases an organization is preparing to submit. And with enough data, IDRE selection can increasingly become a data-informed decision.

Prioritization becomes more important as volume grows

Growing dispute volume does not mean every potential dispute should receive identical operational treatment. Providers can consider expected reimbursement opportunity, filing cost, payer behavior, service type, historical outcomes, IDR entity selection, and available supporting evidence when deciding where resources should be focused.

Another clear factor is eligibility:

• Non-initiating parties challenged eligibility on approximately 42% of disputes initiated during the second half of 2025, and approximately 19% were ultimately found ineligible. Common reasons included failure to complete the mandatory cooling-off period and disputes governed by specified state law or an All-Payer Model Agreement.
• At several million disputes annually, even modest improvements in eligibility determination can create significant operational value.

The reduction in the administrative fee to $15 makes prioritization even more relevant. A larger universe of economically viable disputes creates a larger inventory that must be evaluated and managed.

For sophisticated operators, a larger inventory for review should not be an issue. But for those less advanced/automated organizations, deploying a governance foundation will be key.

Strategy at scale through automation

Automation has always had an obvious role in Federal IDR because of the administrative workload associated with deadlines, documentation, filing, communications, and status monitoring.

Organizations processing thousands or hundreds of thousands of disputes cannot consistently apply sophisticated decision-making through manual review alone. Automation helps:

• Evaluate eligibility
• Distinguish Federal vs State IDR
• Monitor cooling-off periods
• Assemble payer, service, QPA, and historical outcome information
• Surface relevant IDRE performance
• Prioritize cases based on expected reimbursement

CMS is also introducing more automation into the Federal IDR environment, including validations designed to identify duplicate or potentially ineligible disputes earlier. The IDR Gateway will further centralize dispute management, tracking, and notifications.

For providers, automation has value beyond reducing manual labor. Automation provides the infrastructure required to apply strategy consistently across a rapidly growing dispute inventory.

What 2025 may be telling us about what comes next

The 2025 CMS data shows a Federal IDR process that looks materially different from its earliest years.

• Volume continues to rise while processing speed improves.
• IDR capacity has expanded.
• The historical backlog has been substantially reduced.
• CMS is publishing richer information, including IDRE data that can support more sophisticated decision-making when determining IDRE selection.

Those developments shift the operational focus for providers, where success may increasingly depend on which disputes organizations pursue, how accurately they determine eligibility, how effectively they prioritize inventory, how they select IDR entities, and how well they use historical data to inform decisions.

Organizations that can combine those strategic capabilities with scalable automation may be best positioned for the next phase of Federal IDR.

Primary sources

This blog is grounded in CMS public reporting, the Q2-Q4 2025 Federal IDR Public Use Files, and the June 2026 Federal IDR Operations final rule. Several figures and observations are derived from analysis of the Q2, Q3, and Q4 2025 CMS Federal IDR PUF datasets. The 2026 volume range is directional and should be presented as a planning scenario rather than a forecast with precise certainty.

Key public sources include:

1. CMS Federal IDR Reports and Public Use Files
2. CMS Supplemental Background on Federal IDR, Q1-Q2 2025
3. CMS Supplemental Background on Federal IDR, Q3-Q4 2025
4. CMS No Surprises Notices
5. Federal Register: Federal Independent Dispute Resolution Operations Final Rule, June 4, 2026

Want to continue the discussion? Schedule a chat with Seth.