Four years into the No Surprises Act, everyone working inside the Independent Dispute Resolution (IDR) process — providers, payers, and certified IDR entities alike — agrees on two things. First, the law has done real good, shielding patients from a wide swath of surprise out-of-network bills. Second, dispute eligibility remains the process’s most persistent headache.
At QMACS, we see this friction firsthand. We help emergency medicine and other specialty groups manage the revenue cycle work that surrounds every IDR filing, and eligibility issues are consistently where time, money, and reimbursement get lost. This is exactly the terrain our IDR and denial-prevention teams operate in every day.
Eligibility Disagreements Cost Everyone
When a dispute is found ineligible, nobody wins. Providers lose the time and expense of preparing a filing that never gets adjudicated. Payers spend resources contesting it. And the certified IDR entities (IDREs) responsible for arbitration have to divert attention away from the merits of a case just to sort out whether it belongs in the federal process at all — slowing the whole system down.
Cutting down on ineligible filings, and making sure the disputes that are filed carry the documentation needed to resolve eligibility quickly, benefits every party in the process. That’s a shared goal, but reaching it takes each participant doing their part — which is precisely why practices increasingly lean on a partner like QMACS to get the filing right the first time.
What the Numbers Actually Show
Government data tells a more encouraging story than the headlines suggest. CMS’s Center for Consumer Information & Insurance Oversight (CCIIO) reported that roughly 69% of disputes were ruled ineligible in the first half of 2022. By the back half of 2024, that figure had fallen to 20%, and it dropped further to 19% in the second half of 2025. The most recent CCIIO data, covering January through May 2026, puts ineligibility at just 16% of disputes (222,599 of 1,354,911).
It’s worth clearing up a common point of confusion: the oft-cited claim that “40% of disputes are ineligible” doesn’t hold up against the government’s own figures. That number appears to blend two different statistics — the rate at which eligibility gets challenged (42% in the second half of 2025) with the rate at which disputes are actually found ineligible (19%). A challenge isn’t the same as a finding, and treating the two as interchangeable more than doubles the apparent problem. More challenges aren’t necessarily a bad sign, either — they often reflect payers engaging more actively with the process and backing their objections with details, like Medicare or Medicaid involvement, that only the plan may have on hand and that IDREs need to make an accurate eligibility call.
Want to protect your revenue in an increasingly complex reimbursement environment? Contact QMACS today.