As the No Surprises Act’s independent dispute resolution (IDR) process has matured, discourse has abounded, with much of the narrative focused on whether providers are overusing the system to maximize reimbursement.
To be sure, abuse is possible, and inappropriate use of IDR should be addressed. But focusing on fringe cases of abuse misses a more immediate and arguably more pervasive problem: many provider organizations are not getting the access to IDR they’re entitled to because the process is too difficult to navigate effectively at scale.
Unfair access to fair pay
IDR was designed to create more fairness in out-of-network reimbursement and provide a balancing mechanism for market rates when providers and payers cannot agree on payment. In theory, it serves as an important backstop for those providing care.
In practice, however, it is highly procedural, documentation-heavy and resource-intensive. Providers must determine which claims are appropriate to pursue, assess eligibility, assemble supporting data, meet strict timelines and build case-specific arguments in a complex and evolving regulatory environment.
Beyond workflow complexity, there is also a capital burden embedded in the process. Pursuing disputes can require upfront fees and sustained administrative investment well before any reimbursement outcome is realized.
One government estimate puts the average administrative cost for submitting IDR materials at $857 per dispute. Even as CMS recently dropped the administrative fee amount, there is still a significant financial burden associated with submitting IDR claims. That may be manageable for large organizations with dedicated teams, but it can be much harder for smaller provider groups already operating under resource constraints.
The result is a structural access problem. Provider groups with the staff, systems, money and operational sophistication to manage the complexity of IDR are well-positioned to participate, while smaller provider groups, including specialty providers and rural practices who could stand to benefit the most from reimbursement recovery, can be effectively shut out.
Recent data reinforce the point. According to a 2025 survey from AHIP and the Blue Cross Blue Shield Association, only 6% of qualified No Surprises Act claims entered federal IDR arbitration in 2024. Of those that are submitted, large investor-backed provider groups account for a disproportionate share.
This lopsidedness is why the next phase of IDR should not only be about ensuring a compliant process, but expanding practical access to achieve the intended goal of rebalancing the market.
Without smarter technology, IDR risks becoming a system that is inaccessible to the organizations that can benefit most. That would run counter to the law’s broader intent. The future of IDR should be about giving all providers better tools to access the system as it was intended, while advancing human-led technology that helps the process be executed correctly and compliantly.
IDR is uniquely complicated, and basic automation only solved part of it
IDR’s administrative burden stems from its complexity. IDR is not a simple claims workflow. Providers must make multiple high-stakes decisions before and during the dispute process, including whether a claim is eligible, whether it is worth pursuing, what a reasonable offer should look like, what data and context belong in the submission, and how to file a persuasive case that is also compliant.
To be sure, legacy revenue cycle management technology helped move what had been a highly manual process into a more manageable workflow. Providers gained tools to track deadlines, organize disputes and standardize portions of submissions. That was meaningful progress, especially in a system with strict timelines and repetitive administrative requirements.
But workflow management is not the same thing as decision support. Legacy tools did not fully solve the parts of IDR that are uniquely difficult and resource-intensive, such as identifying whether a claim belongs in a state or federal IDR process in a changing legal landscape, determining a defensible offer, and tailoring submissions to the specific facts of each case.
Basic automation, which doesn’t account for context, can’t adequately support these workflows. As a result, even providers with some technology in place may struggle to scale IDR participation in a way that is strategic, compliant and sustainable.
The shift: From workflow automation to AI-enabled decision support
The next phase in the evolution of IDR technology is more purpose-built. It is not just about digitizing workflow. It is about helping providers make better decisions throughout the process, file the right claims at scale and do so more effectively.
Used thoughtfully, AI can support claims identification and eligibility review, reimbursement offer recommendations, position statement development, compliant batching, workflow prioritization and more structured payer communication. That is a meaningful leap from simply moving paperwork through a system faster.
Rather than relying on rigid rules or blanket charge-based strategies, these systems can incorporate a broader range of inputs, including provider background, service codes, patient acuity, payer history, provider direction and prior IDR outcomes, to shape both the reimbursement case and the offer amount. That makes the process more tailored, more defensible and more likely to reflect the real circumstances of the care that was provided.
This is where AI matters, not as a replacement for expertise, but as a way to make expertise more scalable. Particularly for smaller provider groups with limited administrative capacity, it can mean the ability to participate more effectively in a reimbursement environment that has become too complex to manage manually.
In that sense, smarter technology is an access tool, not simply a productivity tool. It can help level the operational playing field by reducing the extent to which success in IDR depends on having outsized administrative infrastructure.
What a better process looks like for providers and payers
A more mature IDR technology stack should benefit both sides.
For providers, it means easier identification of appropriate disputes, less wasted effort on weak or ineligible claims, and more complete, claim-specific submissions. For payers, it means better-organized disputes, more legitimate claims, clearer documentation and a more consistent basis for review.
This matters because when IDR participation depends too heavily on staffing capacity or operational sophistication, the process absorbs time and resources that do little to improve outcomes.
A more efficient approach would reduce administrative overhead for both providers and payers, lower avoidable costs across the system and make dispute participation less dependent on organizational scale. That creates a fairer, more functional process for everyone, while especially helping smaller provider groups, specialty providers and rural practices to participate more consistently.
The broader opportunity is to make IDR more usable, consistent and fair by improving the quality of what enters the system in the first place. Smarter, human-led technology can help make that possible. And if it does, the future of IDR will be more accessible, more effective and more sustainable.
Photo: da-kuk, Getty Images
Josh Folds is the Co-Founder and Chief Operating Officer at Pivotal Health, a healthcare technology company helping providers achieve fair reimbursement via their full-service Independent Dispute Resolution (IDR) platform.
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