Employer plans are seeing a sharp rise in health care payment disputes under the No Surprises Act’s (NSA) independent dispute resolution (IDR) system. CMS data for the second quarter of 2025 show employer plans were involved in 524,052 disputes, a 119% increase from Q2 2024.
A preliminary analysis shows that when self-funded plans lose these disputes, they pay an average of 23 times the qualifying payment amount (QPA) — often 20 to 40 times the typical in-network rate. Fully insured plans that lose fare even worse, paying an average of 44 times the QPA.
Although the NSA was created to protect patients from surprise bills, the IDR process — intended as a last resort — has seen explosive growth in volume. Providers initiate the vast majority of disputes and frequently prevail at significantly higher payment levels, adding substantial costs and administrative burdens for employer-sponsored plans.
“Whatever the good intentions of the NSA, the increase in disputes is placing real pressure on employers,” said MedBen President, COO & CPO Caroline Fraker. “We regularly engage with federal policymakers on these issues and believe targeted refinements to the IDR process are essential to reduce unnecessary disputes.”