The Centers for Medicare & Medicaid Services (CMS) just released new data from the first half of 2025 on the No Surprises Act’s Independent Dispute Resolution (IDR) process, and the numbers are staggering.

Nearly 1.2 million disputes were filed in just six months, a 40% increase from the prior period. And it should come as no surprise that the same private equity-backed providers and IDR middlemen dominated the system to pad their bottom lines.

Congress created IDR to resolve payment disputes in limited instances while keeping patients out of the middle. Instead, a handful of bad actors have turned what was meant to be a mechanism of last resort into a profit center, driving billions in wasteful spending that hits employers and workers through higher premiums and out-of-pocket costs.

Healthcare Dive provides a preliminary analysis of the new data. Among the key takeaways (emphasis added):

  • The top 10 initiating parties represented almost 70% of all disputes in the first six months of 2025, according to the latest CMS data file released on Wednesday.”
  • “The top three initiating parties — HaloMD, a middleman that takes on IDR disputes on behalf of providers, along with PE-backed providers Team Health and SCP Health — accounted for approximately 44% of all disputes initiated in the first half of last year, according to the CMS.”
  • “Combined with the fact that providers win the large majority of disputes — a whopping 88%, even higher than the 85% in the last six months of 2024 — and are paid three or four times above comparable in-network rates when they win, that’s a big issue for insurers.”
  • “The lion’s share of disputes continue to be submitted by a handful of mostly private equity backed-provider groups, raising concerns IDR is being exploited for profit.”
  • About 20% of disputes submitted in the first six months of 2025 were actually ineligible for IDR, the CMS said. Notably, the percentage of ineligible disputes has been dropping as arbiters get better at processing eligibility reviews. But they’re still cluttering up the process, regulators say.”

Read the full analysis from Healthcare Dive here. Learn more about HaloMD’s exploitation of the IDR process here.