The No Surprises Act is a federal law intended to protect patients from “surprise medical bills,” a term that refers to situations in which patients receive out-of-network care unintentionally and through no fault of their own, resulting in unexpectedly high bills. The law is applicable to two specific circumstances:
- When a patient experiencing a medical emergency is taken to an out-of-network facility to receive emergency care.
- When a patient receives non-emergency services at an in-network facility but unknowingly receives care from an out-of-network provider operating within that facility.
Under the law, an out-of-network provider in one of these situations may only charge a patient the in-network cost-sharing amount specified in the patient’s health insurance plan. The provider and insurer are then left to negotiate a payment rate between themselves. For situations in which a provider and an insurer cannot agree on a rate, the law, which took effect in 2022, created an independent dispute resolution (IDR) process under which negotiations are arbitrated by a private third-party firm known as an “IDR entity.”
The IDR process begins when one party submits a list of disputed line items for eligibility consideration by an IDR entity. Each line item includes a service code identifying the procedure being disputed, the date of service, and the qualifying payment amount (QPA), which is the median contracted rate that the insurer party to the dispute pays in-network providers in the disputing provider’s geographic area for the service code. The provider and insurer each make a payment offer for every disputed line item, and the IDR entity selects a winning offer from each pair of offers. The insurer then pays the provider the winning offer amount, which is reported in IDR public use files as a factor of the QPA, and the losing party pays a substantial service fee to the IDR entity.
IDR determinations frequently lean in favor of providers and result in payments that are several times higher than typical QPAs. Some providers argue that QPAs are artificially low and that therefore IDR offers which substantially exceed the QPA are appropriate. In Arkansas in 2025, providers won 87.6% of disputed line items, and the median winning offer was 4.85 times the QPA. Nationwide, providers won about 85.6% of disputed line items in 2025, and the median winning offer was 3.99 times the QPA.
This interactive dashboard displays publicly available data on federal IDR determinations involving Arkansas providers in 2025.
DASHBOARD VIEWS AND DEFINITIONS
Dashboard Views:
- The default provider selection dropdown displays only the 25 providers with the most disputes, but all providers in the source data can be viewed by deselecting “Top 25 Only.”
- IDR data are reported on a quarterly basis. The default view displays data for all four quarters of 2025, but data can be filtered by quarter.
- The Overview view displays summary data for all Arkansas providers or for a selected provider in the selected quarter(s). In the bar graph, a split decision indicates disputes in which the IDR entity selected the provider’s offer for some line items in the dispute but selected the insurer’s offer for others.
- The Offers vs QPA view by default displays the range of offers made by all Arkansas providers, the range of offers made by all insurers, and the range of offers selected by the IDE entities. When an individual provider is selected, the view displays the range of offers made by the selected provider, the range of offers made by the insurers involved in that provider’s disputes, and the range of offers selected by the IDR entities.
- In the Service Codes, Insurers, and IDR Entities views, bar charts and tables containing additional information are available.
Definitions:
- CPT/HCPCS/Service Codes: For the purposes of insurance payment, medical services and supplies are assigned service codes which payers associate with certain payment rates. In the IDR process, disputes are filed with one or more individual line items tied to a Current Procedural Terminology (CPT) code or Healthcare Common Procedure Coding System (HCPCS) code.
- Qualifying Payment Amount (QPA): The median contracted rate an insurer pays in-network providers in a disputing provider’s geographic area for a CPT code appearing in a dispute. The QPA includes both the insurer’s liability and the patient’s cost sharing for a service. The QPA for a given CPT code can vary widely between insurers and across geographic areas.
- IDR Entity: A private firm that provides third-party arbitration services through the IDR system. There were 17 IDR entities in 2025. Both the provider and insurer must pay a fee to the IDR entity to initiate the IDR process, and the party that loses the dispute pays an additional fee after the determination is made. Provider win rates vary widely across IDR entities, and IDR entities do not have to disclose their decision rationale.
- Insurer/Provider/Winning Offer: During the IDR process, the provider and insurer each make a payment offer to the IDR entity, which then decides between the two offers.
- Insurer Offer: The rate proposed by the insurer for consideration by the IDR entity. Insurers typically offer a rate equal to or slightly more than the QPA.
- Provider Offer: The rate proposed by the provider for consideration by the IDR entity. Providers typically offer a rate that is several times the QPA.
- Winning Offer: The offer selected by the IDR entity for final payment. The IDR entity cannot split the difference between the two offers; it must select either the insurer’s rate or the provider’s rate. “Winning” a dispute does not necessarily mean the IDR entity felt the winning offer was fair, only that it was more appropriate than the alternative offer. IDR entities are not required to provide rationale behind their decisions.
- Line Item: Disputes are itemized by specific services (identified by service codes) delivered on specific dates. Each line item is a single disputed service code, with its own QPA and set of offers. A single dispute may involve multiple line items, and the IDR entity makes a separate determination for each.
- Win Rate/Line Item Win Rate: The percentage of all Arkansas providers’ disputed line items or an individual provider’s disputed line items for which the provider offer was selected by the IDR entity, in the selected quarters.
About the Data
The data presented here are sourced from the Centers for Medicare and Medicaid Services’ federal IDR public use files.
Data are reported quarterly, and all quarters of 2025 are included in the dashboard. Each quarter’s data consist of disputes resolved in that quarter, not disputes submitted in that quarter.
Each dispute can contain multiple line items, for each of which the IDR entity makes a separate determination. All win rates presented are calculated as the percentage of line items for which the IDR entity selected the provider’s offer.
Some disputes list the individual physicians operating under a facility or group practice as the provider. In this dashboard, such disputes are rolled into the numbers of the facility or group practice.
Provider names were taken directly from the source data. Near matches were merged into a single provider. Some providers submit disputes under a legal name instead of the name under which they do business.
Some providers use third-party firms to administer disputes on their behalf. When this is the case, the provider’s name is still used in the dispute, but the third-party firm’s email domain is listed instead of the provider’s email domain in the IDR public use files. This is the only indication of a third party’s involvement available in the source data. Email domains are included in the dashboard and may indicate that third-party firms were used.
The dashboard displays both median and mean offers as a multiple of the QPA. The median is the middle value of a set of values, whereas the mean is the average of a set of values. Because the source data contain numerous outlier offers, mean offers are generally substantially greater than median offers.