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.
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:
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.
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:
In the end, everyone should prepare for a Federal IDR environment measured in millions of disputes annually.
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.
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:
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.
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:
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.
The 2025 CMS data shows a Federal IDR process that looks materially different from its earliest years.
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.
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:
Want to continue the discussion? Schedule a chat with Seth.