ICYMI: Private Equity-Backed Providers and Profit-Enhancing Middlemen Have Made Manipulating the IDR Process a Business Model

Jun 30, 2025 | Arbitration, Blog Post, Private Equity

Certain health care providers—particularly large, private equity-backed groups—are increasingly dominating the federal Independent Dispute Resolution (IDR) process established under the No Surprises Act, according to new data from the Centers for Medicare & Medicaid Services (CMS) and analyzed by researchers at Georgetown University. The latest analysis highlights the ongoing misuse and abuse of the process—continued surge in arbitration filings, sky-high final payments that overwhelmingly favor providers, and growing use of third-party IDR firms—raising alarms about the consequences for consumer premiums and health care affordability.

While the No Surprises Act has effectively prevented unexpected medical bills, this latest CMS data reinforces concerns that a growing number of providers and IDR-specific middlemen are leveraging IDR to maximize payments and undermining the law’s cost-savings goals.

Below are key insights from the analysis. To read more, click here.

IDR was supposed to be a last resort for payment disputes. Instead, providers continue to flood the system with claims, including a sizeable portion that are ineligible for IDR in the first place.

  • “The six-month total for filed cases (586,581) in Q1 and Q2 of 2024 is nearly as high as all of 2023 (657,040 filed cases)”.
  • “The rate of filed cases challenged as ineligible was higher in Q1 and Q2 of 2024 (45 percent) than in all of 2023 (37 percent).

Private equity-backed providers rely on IDR for extracting higher payments from employers and health plans.

  • “In 2023, the rate of providers prevailing rose from 70 percent of resolved cases in Q1 to 87 percent in Q4. Rates in 2024 matched the latter levels: providers won 88 percent and 83 percent of resolved cases in Q1 and Q2, respectively.”
  • “As in 2023, resolved IDR cases were predominantly from a few large provider organizations – mostly backed by private equity. Radiology Partners was the most frequent user of IDR in Q1 and Q2 of 2024, followed by Team Health, SCP Health, AGS Health, and HaloMD. Combined, these five organizations account for nearly two-thirds (63 percent) of resolved cases.”
  • “In addition to a high volume of cases, these top five provider organizations won the vast majority of their disputes, with offer amounts at least two times greater than QPA. Radiology Partners significantly outmatched other provider groups, with a median prevailing offer at 631 percent of QPA and 610 percent of QPA in the first half of 2024.”
  • “In Q1 of 2024, the median prevailing provider offer was 383 percent of the QPA. This rose nearly 70 percentage points in Q2, with a median prevailing provider offer of 447 percent of the QPA.”

Rather than supporting rural doctors, IDR has become a tool for private equity–backed groups and IDR-specific middlemen to implement business models that extract higher payments.

  • “Third-party claims management companies account for at least a fifth of resolved cases.”
  • “HaloMD was specifically created ‘to be the leading provider of IDR services.’ The company illustrates the rise of profit-enhancing middlemen focused on the IDR process. While large provider organizations like Radiology Partners and TeamHealth have the internal resources to manage disputes, HaloMD and other third-party organizations can take on the administrative burden for smaller providers—offering them greater opportunities to engage in IDR.”
  • “In 2023, HaloMD appeared in only 1 percent of resolved disputes, whereas in Q2 of 2024, HaloMD initiated 10 percent of disputes. HaloMD’s prevailing offers increased substantially as well: in Q1 of 2023, the organization prevailed in 17 percent of resolved cases, but their win rate steadily increased to 84 percent in Q4 of 2023. This success rate appears stable, reaching 89 percent and 81 percent in Q1 and Q2 of 2024, respectively.”
  • “As one provider group familiar with the IDR process noted in a previous Forefront piece, ‘smaller practices have less ability to access IDR than do larger, well-capitalized organizations.’ This trend may be shifting with the rise of IDR-specific middlemen.”

The bottom line: The most recent data confirms earlier warnings: A small group of private equity-backed provider groups are increasingly turning to IDR over direct negotiation, driving up payment amounts. At the same time, a new class of third-party actors—IDR-focused, profit-driven middlemen—are accelerating claim volume and further entrenching these dynamics. A strong IDR operations rule is urgently needed to restore balance and prevent further cost shifts to consumers.

For more information on the No Surprises Act, visit stopsurprisebillingnow.com.