Physicians will not face any fee increases in 2025 for the federal Independent Dispute Resolution (IDR) process under the No Surprises Act, according to a recent announcement by the Centers for Medicare & Medicaid Services (CMS).

For the upcoming year, the administrative fee per party per dispute remains at $115. Certified IDR entities will continue to charge between $200 and $840 for single payment determinations, and between $268 and $1,173 for batched determinations.

This federal Independent Dispute Resolution process enables physicians to challenge the initial payments made by health plans for certain out-of-network services. A certified arbitrator reviews the case details and, after receiving input from both the provider and the payer, determines the final payment amount.

The $115 administrative fee, which each party must pay and is nonrefundable, reflects a significant reduction from the previously proposed $350 rate. The Texas Medical Association (TMA) successfully challenged this fee hike through litigation, and later filed formal comments opposing a proposed $150 fee in October 2023 and January 2024.

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Although the Departments of Health and Human Services, Labor, and Treasury have chosen to maintain current administrative and IDR entity fees for now, many physicians remain concerned about the practical burdens of participating in the independent dispute resolution No Surprises Act process—especially the time, financial, and operational challenges it presents.

“It impacts cash flow,” said Christopher Cook, DO, who has handled around 900 IDR cases. “You’re essentially sitting on money you can’t use for your practice or other needs.”

Dr. Cook pointed out that independent practices, like his own, are especially affected. Larger organizations may be better equipped to handle provider services independent dispute resolution cases, but smaller groups face long hours and limited resources. He often works late nights or devotes full weekends to managing the arbitration process.

Emergency medicine physician Carrie De Moor, MD, of Frisco, experienced similar issues when running her own practice, which closed in 2020 partially due to difficulties with insurance reimbursement. In disputes with health plans, she had to either cover legal costs or navigate the system herself.

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“Small practices just can’t keep up,” Dr. De Moor said. “They don’t have the bandwidth to continue the fight.”

Still, she remains committed to pushing back against unfair independent dispute resolution payor tactics.
“You have to push back, or they’ll continue to take advantage,” she said. “In that sense, it’s still worth going through the process.”

Organizations like No Surprise Bill offer expert support with Independent Dispute Resolution, guiding practices through each phase of the process—including documentation preparation, strategic negotiation, and regulatory compliance. Their team works closely with providers to reduce administrative burdens, minimize fees, and improve the likelihood of favorable determinations. By leveraging deep knowledge of payer behavior and IDR procedures, they help medical practices navigate disputes efficiently while maintaining cash flow and maximizing revenue retention.

Since 2021, TMA has successfully sued federal agencies multiple times over implementation issues related to the No Surprises Act’s Independent Dispute Resolution framework between physicians and payers.

To learn more about payer-related topics, explore TMA’s continuing medical education programs. For support on payment matters, contact the Physician Payment Resource Center.