The No Surprises Act's independent dispute resolution process cost employer plans $8.39 billion in 2025, according to a new analysis.
Researchers at the Employee Benefit Research Institute combed federal IDR data and found that these additional costs equal about 63 cents per $100 spent by employer-based insurance plans. The total includes $4.73 billion in costs incurred in the first half of the year as well as $3.66 billion in the second half of 2025.
Even when EBRI analysts used different thresholds to exclude outlier awards, such as a costs that were unusually high, they still landed on an estimate of at least $8.02 billion, per the study.
The researchers note that this data doesn't necessarily paint the full picture, as it only encompasses cases that proceeded to IDR. The study doesn't include information on claims that were settled outside of arbitration, administrative costs, any changes in networks or provider rates or the cost associated with patient protections.
The study calculates additional cost by taking the IDR award amounts and subtracting the plan's initial payment and any cost-sharing from the patient.
"These new data provide a clearer picture of what health plans owe for out-of-network services beyond their initial payments, after accounting for patient cost sharing,” said Paul Fronstin, Ph.D., director of Health Benefits Research at EBRI, in the announcement. “Separating those amounts from arbitration awards allows us to measure additional plan obligations more directly."
The study also doesn't project the impact of IDR on premiums, and the researchers said that having greater insight into the administrative expenses and other ancillary costs would be necessary to understand how the No Surprises Act's processes may be impacting patients' costs directly.
The IDR processes has gained increasing scrutiny from health plans and plan sponsors as the number of disputes, and their associated payouts, rise. When a claim reaches the arbitration phase, the results overwhelming favor providers, as they won in 85% of disputes last year.
An analysis from Georgetown University, released in August, estimated that total costs associated with IDR reached $22 billion in 2025. There were 2.6 million disputes initiated in 2025; by comparison, federal estimates projected about 22,000 cases annually reaching the arbitration phase.
Providers have pushed back on criticism of IDR, arguing that the root cause is payers undercutting them during the opening negotiation phase by setting low qualifying payment amounts for claims.