How the federal Independent Dispute Resolution program has actually grown, straight from CMS's own published numbers — tracked here so the trend is easy to see in one place.
Figures below come directly from the Departments' bi-monthly Federal IDR updates, current through the report dated May 31, 2026. CMS's most recent bi-monthly release (as of July 31, 2026) reports 394,140 disputes initiated in July 2026 alone (up 24% from June 2026's 318,421) and 371,715 closed in July — but its cumulative-total table in that release appears to duplicate an earlier report's figures rather than reflect the new period, so we've held it out of the chart below rather than publish a number we can't verify. We'll update this page once CMS corrects or republishes it. Always cross-check time-sensitive figures against the official CMS reports page →
Each row is a two-month reporting window. “Cumulative initiated” is the running total since the program launched.
| Report date | Initiated (period) | Closed (period) | Cumulative initiated |
|---|---|---|---|
| May 31, 2025 | 435,259 | 509,510 | 3,324,051 |
| Jul 31, 2025 | 419,716 | 515,772 | 3,743,767 |
| Sep 30, 2025 | 439,860 | 497,121 | 4,183,627 |
| Nov 30, 2025 | 451,329 | 443,773 | 4,634,956 |
| Jan 31, 2026 | 516,241 | 506,242 | 5,151,197 |
| Mar 31, 2026 | 578,758 | 541,142 | 5,729,954 |
| May 31, 2026 | 606,079 | 559,008 | 6,336,032 |
Volume has climbed almost every period on record, from roughly 3.3 million cumulative disputes in May 2025 to over 6.3 million by May 2026 — more than 3 million new disputes in just twelve months. That's an order of magnitude beyond what regulators originally projected when the program launched (an early estimate put annual volume around 17,000 disputes).
Closures have kept pace with, and at times outpaced, new filings. From September 2025 through January 2026, CMS's own releases note that certified IDR entities were closing about as many or more disputes than were being initiated each period, explicitly framing this as clearing the program's backlog. That pattern reversed somewhat by spring 2026, when initiations (578,758 in the Feb–Mar 2026 window) again pulled ahead of closures (541,142) — worth watching, since a return to filings outpacing closures is exactly the dynamic that built the original backlog.
None of this bi-monthly data breaks out payment determinations by outcome (provider-favorable vs. issuer-favorable) or dollar amounts — for that, the quarterly Public Use Files with line-item detail are the better source. The sections below pull from two independent analyses of that PUF data.
Analysis of CMS's Federal IDR Public Use Files, 2023–2025.
| Specialty | 2023 | 2024 | 2025 |
|---|---|---|---|
| Emergency Department Services | 235% | 280% | 315% |
| Radiology | 409% | 559% | 468% |
| Pathology & Laboratory | 100% | 342% | 416% |
| Anesthesia | 199% | 247% | 315% |
| Surgery | 712% | 1,009% | 1,355% |
| Neurology & Neuromuscular | 974% | 1,464% | 2,450% |
| Plastic Surgery: Breast Implant/Reconstruction | 1,495% | 2,468% | 3,239% |
Plastic surgery is a subset of the Surgery row above, shown separately because of how far it sits above the specialty average.
| Cost component | Amount | Period covered |
|---|---|---|
| Payment awards above the QPA | $15.6B | 2023–2025 (2022 data unavailable) |
| Internal administrative costs (est.) | $4.2B | 2022–2025 |
| IDR administrative & entity fees | $2.7B | 2022–2025 (entity fees from 2023) |
| Total | $22.4B | 2022–2025 |
2025 alone accounted for $16.6 billion of that total — roughly 3.5x the 2024 figure — driven by dispute volume up 77% year-over-year and total award dollars up 264%, more than triple the rate of volume growth. That gap is the story: it's not just that more disputes are happening, it's that a growing share of them carry unusually large awards. Three organizations — Radiology Partners, HaloMD, and TeamHealth — accounted for over three-quarters of resolved dispute lines in 2025.
Read the full Georgetown CHIR analysis →
View the full CMS reports & Public Use Files →