Since the No Surprises Act took effect in 2022, it’s changed a lot about how providers manage out-of-network billing. Designed to protect patients from unexpected medical bills, the law also brought a big wave of administrative complexity for providers. The Independent Dispute Resolution process, in particular, has become a key piece - but it's not easy to manage at scale.
At Macedon Technologies, we’ve been watching this system mature. We're working with healthcare organizations of all sizes to help them move beyond spreadsheets and manual email reviews. With the Appian platform, we build custom, award-winning tools that streamline NSA workflows and make it easier to stay compliant while recovering more revenue.
Based on CMS and FHAS data from the first half of 2024:
Interestingly, the top 10 initiators now account for 69% of disputes, down from 76%. That shift suggests more smaller and mid-sized providers are jumping in - highlighting the need for scalable, accessible solutions.
Metric |
Value |
Trend |
Total IDR Disputes Filed |
610,498 |
▲ 56% from H2 2023 |
Payment Determinations Made |
348,607 |
▲ 67% YOY |
Disputes Closed |
460,774 |
▲ 260% from H2 2023 |
Share by Facilities |
14% |
▲ from 10% |
Eligibility Challenges |
45% |
▲ from 37% |
Top 10 Initiator Share |
69% |
▼ from 76% |
From email overload to tight timelines, the process today is still heavy:
We’ve heard firsthand how this plays out:
Stage |
Manual NSA Process |
Automated NSA Workflow |
Email Review |
Inbox flooded, slow sorting |
Auto-ingested, routed |
ONP Initiation |
Manual email + PDF |
Auto-generated + submitted |
IDR Filing |
CMS login, manual form entry |
Pre-populated via automation |
IDRE Selection |
Rejected entities require repetitive logins |
Auto-tracked with optimized re-selection |
Eligibility Review |
Time-intensive decision trees |
Rule-based logic to assess State vs Federal |
Position Statement Creation |
Managed by internal/external legal teams manually |
Auto-generated with templated legal language |
Deadline Management |
Calendar reminders and spreadsheets |
System-assigned tasks, alerts, escalations |
This is where automation really starts to make a difference. At Macedon, we’re building tools that:
The ROI we’ve seen with clients using our No Surprises Act solution is compelling:
The IDR system is evolving fast. The question isn’t whether it’s worth investing in efficiency - it’s how long providers can keep up without it. Automation isn’t about replacing teams. It’s about helping them work smarter, scale better, and avoid the risks that come with a process this complex.
If your organization is thinking about what’s next with NSA, we’d love to share what we’re learning - and how we’re helping others navigate it. Schedule time with me now to learn more.