By the Numbers: How Private Equity and IDR Middlemen Abuse the No Surprises Act and Cost Americans Billions

Jan 13, 2026 | Arbitration, Blog Post, Private Equity

Congress and the President enacted the No Surprises Act to protect patients from outrageous medical bills and create a balanced, predictable system for resolving payment disputes between health plans and providers, while lowering costs. Instead, some private equity-backed provider groups and profit-seeking middlemen are abusing the law’s arbitration process to pad their bottom lines, driving up health care costs by billions of dollars for American employers, workers, and families.  

Here’s what to know for 2026: 

  • $5 Billion+ in Added Costs: Since 2022, the federal Independent Dispute Resolution (IDR) process has generated more than $5 billion in excessive costs, which translates into higher premiums, deductibles, and out-of-pocket expenses for American workers – without adding value.
  • 17,000 vs. 2,291,586: Federal regulators initially projected 17,000 IDR cases per year. In reality, there were 2,291,586 cases in 2025 (through Nov. 30), 13,000% higher than expected. 
  • Over 40% of Disputes From a Small Handful of Companies: 44% of IDR filings in the first half of 2024 came from just three private equity-backed provider groups: TeamHealth, SCP Health, and Radiology Partners. 
  • Providers Win More Than 85% of Cases: Providers prevail in more than 85% of cases, a lopsided success rate that suggests the system is anything but neutral.  
  • 459% of In-Network Rates: In the fourth quarter of 2024, the median payment awarded to providers was 459% of the qualifying payment amount (QPA), which is the benchmark based on typical in-network rates for the same service in the same market. 
  • 934% of In-Network Rates: The “win rate” for HaloMD—founded after the enactment of the No Surprises Act and which markets its AI tools and tactics to help providers “maximize” out-of-network reimbursements—jumped from 17% in 2023 to over 84% in 2024 with median awards reaching 934% of the QPA. 
  • Nearly 40% of Disputes Identified As Ineligible: Nearly 40% of 2024 IDR disputes shouldn’t have qualified for arbitration, yet many proceeded anyway, leaving employers and health plans to absorb costs for claims that should have been dismissed. 

When arbitration awards skyrocket and inappropriate claims clog the system, those costs cascade directly into higher premiums and rising deductibles, eroding benefits for workers and their families. 

The Coalition Against Surprise Medical Billing (CASMB) is urging the Trump administration to safeguard consumers from inflated arbitration outcomes and price gouging by: 

  • Reducing wasteful spending from ineligible claims by verifying IDR claim eligibility upfront and preventing ineligible disputes from moving forward; 
  • Eliminating conflicts of interest by prohibiting IDR entities with financial ties to providers from becoming or remaining certified IDR entities;
  • Stopping provider behaviors that inappropriately drive up costs for employers and employees; and 
  • Increasing transparency and accountability through better portal access, required explanations and rationales for arbitration decisions, sharing the information used to make determinations, and performance metrics with consequences for misuse. 

 The No Surprises Act was supposed to end predatory medical billing and lower health care costs. Unfortunately, the data clearly shows that a handful of bad actors are manipulating IDR for profit, and American workers are footing the bill. 

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