How many IDR disputes have been filed?
Verdict Consulting Group Research · Updated
Answer
More than 5.1 million disputes had been submitted to the federal IDR process as of January 31, 2026, the Departments reported in the Federal IDR Operations rule, citing CMS data. CMS reports 1,372,563 disputes initiated from July 1 to December 31, 2025 alone. Certified IDR entities found 355,804 disputes ineligible from April 2022 through December 2024.
Detail
The figures
| Measure | Figure | Period | Source |
|---|---|---|---|
| Disputes submitted, cumulative | Over 5.1 million | April 15, 2022 – January 31, 2026 | 91 FR 33902 (citing CMS bi-monthly reports) |
| Disputes submitted, first year | 489,000 | First year of operations | 91 FR 33901 |
| Disputes initiated | 1,186,812 | January 1 – June 30, 2025 | CMS |
| Disputes initiated | 1,372,563 | July 1 – December 31, 2025 | CMS |
| Eligibility challenged by non-initiating party | 976,721 | April 15, 2022 – December 31, 2024 | 91 FR 33902 |
| Found ineligible | 355,804 | April 15, 2022 – December 31, 2024 | 91 FR 33902 |
Reading the numbers
CMS publishes federal IDR data in quarterly public use files and supplemental tables, so totals change with each release; the 2025 second-half figures were released July 22, 2026. CMS reports that the top three initiating parties (HaloMD, Team Health and SCP Health) accounted for about 38% of disputes initiated in the second half of 2025.
Correction (2026-10-10): An earlier version attributed the 5.1 million figure directly to CMS. It appears in the Departments' preamble to the Federal IDR Operations rule (91 FR 33902), which cites CMS's bi-monthly reports.
Read the analysis
Sources
- Federal Register — Federal Independent Dispute Resolution Operations, 91 FR 33900 ()
- Centers for Medicare & Medicaid Services — Supplemental Background on Federal IDR Public Use Files, July 1 – December 31, 2025 ()
- Centers for Medicare & Medicaid Services — Supplemental Background on Federal IDR Public Use Files, January 1 – June 30, 2025 ()
- Centers for Medicare & Medicaid Services — Independent dispute resolution reports ()
General information only, not legal advice. Verdict Consulting Group is not a law firm.