Independent Dispute Resolution (IDR) Fees in 2025

As the No Surprises Act continues to evolve in its implementation, the Independent Dispute Resolution (IDR) process has become a central mechanism in resolving payment disagreements between healthcare providers and insurance companies. In 2025, the structure of IDR and the fees to participate have undergone notable changes, with implications for providers—particularly in specialties like emergency medicine and anesthesiology, where out-of-network billing is more common. Understanding the current IDR fee landscape is essential for stakeholders navigating this still-new regulatory terrain.

The IDR system was introduced to protect patients from surprise medical bills by removing them from payment disputes between providers and payers. When a provider and insurer cannot agree on a payment amount for out-of-network services, either party may initiate IDR. A certified third-party arbitrator then reviews both payment offers and determines the final amount. The goal is to encourage reasonable negotiation prior to arbitration and reduce friction in the billing ecosystem. However, the costs associated with initiating and participating in IDR have become a point of contention ^1–4.

In 2025, the Centers for Medicare & Medicaid Services (CMS) finalized new fee structures for accessing the federal IDR process. The administrative fee to initiate a dispute, which had already seen changes in previous years, is $115 per party per dispute. This non-refundable fee is separate from the actual arbitration fee paid to the certified dispute resolution entity, which typically ranges from $200 to over $800 depending on the complexity of the case and the entity selected. The CMS itself lays forth a detailed, complete list of certified dispute resolution entities ^5–7.

The finalized 2025 IDR fees reflect a broad commitment to fairness, transparency, and access in resolving out-of-network payment disputes. By formalizing administrative and certified entity fees through rulemaking, the departments continue to seek to create a more stable and predictable process while ensuring the financial sustainability of the IDR system, the ongoing goal being to support a balanced approach where both payers and providers can resolve disagreements without burdening patients or discouraging participation due to high fees.

The vision behind these fees is to continue to uphold the intent of the No Surprises Act, protecting patients while promoting equitable provider reimbursement. The process remains essential but strained, with providers prevailing in most disputes and raising concerns about underpayment and flawed qualifying payment amount calculations. Ongoing reforms and technical improvements aim to make the IDR process more efficient, accessible, and fair—reinforcing its role as a critical safeguard in the evolving healthcare landscape ^8,9.

The IDR system in 2025 continues to evolve, including associated fees and rules, and further changes are expected as CMS responds to feedback from stakeholders. As the system matures, ensuring that arbitration remains accessible and fair will be critical to preserving the intended protections of the No Surprises Act.

References

1. Duffy, E. L., Garmon, C., Adler, L., Biener, A. & Trish, E. No Surprises Act independent dispute resolution outcomes for emergency services. Health Aff Sch 2, qxae132 (2024). DOI: 10.1093/haschl/qxae132
2. No Surprises Act Independent Dispute Resolution (IDR) Process Data Analysis for the First Half of 2023. https://www.congress.gov/crs-product/R48058.
3. Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges Final Rule Fact Sheet | CMS. https://www.cms.gov/newsroom/fact-sheets/federal-independent-dispute-resolution-idr-process-administrative-fee-and-certified-idr-entity-fee.
4. New No Surprises Act Independent Dispute Resolution Fees Started on January 1, 2025. https://www.asahq.org/advocacy-and-asapac/fda-and-washington-alerts/washington-alerts/2025/01/new-no-surprises-act-independent-dispute-resolution-fees-started-on-january-1-2025.
5. McKenny, S. No Surprises Act IDR Entity Fees Updated for 2025. Telcor https://telcor.com/no-surprises-act-idr-entity-fees-updated-for-2025/ (2025).
6. Fees to Remain Unchanged for Federal Surprise Billing Dispute Resolution. https://www.texmed.org/Template.aspx?id=65279.
7. List of certified organizations | CMS. https://www.cms.gov/nosurprises/help-resolve-payment-disputes/certified-idre-list.
8. Providers Prevail in Vast Majority of Independent Dispute Resolution Cases. https://www.acr.org/News-and-Publications/Providers-Prevail-in-Vast-Majority-of-Independent-Dispute-Resolution-Cases.
9. Fees set in independent dispute resolution process for providers and payers. Healthcare Finance News https://www.healthcarefinancenews.com/news/fees-set-independent-dispute-resolution-process-providers-and-payers.