IDR AI Insights
Today we’re introducing IDR Insight AI, a new tool from Internet Technology Services (ITS) for the federal Independent Dispute Resolution (IDR) process under the No Surprises Act. It helps providers, billing companies and their reps prepare, file and manage out-of-network payment disputes with health plans, faster and with fewer costly mistakes.
IDR Insight AI brings the latest AI technology to the IDR industry, backed by the engineering experience we’ve built since 2009 across more than 100 client projects from our base in Dana Point, California. We’re now preparing a pilot program with a small group of providers, and this post explains what we built, why, and how to get involved.
The current market
When the federal IDR process launched in April 2022, the Departments of Health and Human Services, Labor and the Treasury expected about 22,000 disputes in its first year. By June 2023 they had received nearly 490,000, according to the U.S. Government Accountability Office.
The volume never slowed. As of July 31, 2026, more than 7 million disputes had been initiated since the portal opened, including 2,145,850 in the first seven months of 2026 alone (CMS IDR reports).
Providers win most of the disputes that reach a decision. In the second half of 2025, providers, facilities and air ambulance providers prevailed in about 85% of payment determinations, and the prevailing offer was higher than the qualifying payment amount (QPA) in about 87% of them (CMS).
Where the market is heading
Volume is still climbing. Georgetown’s Center on Health Insurance Reforms (CHIR) reports that disputes rose 77% from 2024 to 2025 to 2.6 million, and that the first six months of 2026 reached 1.75 million, 50% above the same period of 2025 (Georgetown CHIR). CMS counted 394,140 disputes initiated in July 2026 alone, up 24% from June (CMS).
The rules are changing too. A federal IDR operations final rule published June 4, 2026 cut the administrative fee from $115 to $15 per party per dispute for disputes initiated on or after June 11, 2026. The cut is expected to make the process more accessible to smaller providers and facilities, and the Departments anticipate it may increase dispute volume. The same rule formalizes open negotiation notices, adds a hard cap of 50 items per batched dispute with a new “similar condition” batching test for open negotiations starting on or after November 1, 2026, creates a registry for plans and issuers, and requires standardized remittance codes that show whether a claim is subject to the No Surprises Act (Holland & Hart summary).
Costs are drawing scrutiny. The CHIR study estimates the IDR system cost $22.4 billion from 2022 to 2025, including $16.6 billion in 2025 alone, and notes renewed attention from policymakers (Georgetown CHIR; Medical Economics). The takeaway for providers: more disputes, new paperwork requirements and closer scrutiny all reward filings that are accurate, complete and on time.
The demand that isn’t being met
Eligibility is still the biggest stumbling block. Non-initiating parties challenged the eligibility of 42% of disputes in the second half of 2025, and about 19% were found ineligible, most often because of an unfinished 90-day cooling-off period or because the dispute belonged in a state process (CMS). Since April 2022, more than 1.16 million disputes have been closed as ineligible (CMS).
The process is also dominated by a few large players. The top ten initiating parties filed about 66% of disputes in late 2025 (CMS), and CHIR found that many smaller local practices aren’t using IDR at all. One of the study’s authors said navigating it takes resources most small practices lack, including familiarity with the federal portal (Medical Economics).
Labor is the hidden cost. The federal departments estimated plans’ and providers’ internal costs to submit IDR materials at $857 per dispute (Georgetown CHIR), and one software competitor puts manual filing at 25–40 minutes per claim (Sydra). With the administrative fee now just $15, staff time is the main thing keeping smaller providers on the sidelines.
How IDR Insight AI is different
IDR Insight AI was purpose-built for one job: getting federal IDR disputes right. It combines the latest AI technology with rule logic written specifically for the IDR process, and it works from your data rather than generic boilerplate.
- Fast AI judgment calls before you file. IDR Insight AI reviews each dispute for likely eligibility, the right service and code category, and missing evidence. Anything it isn’t confident about is flagged for human review instead of guessed at.
- Probability-based signals, not hunches. See how likely a dispute is to be worth filing, and where an offer sits relative to the QPA compared with how similar disputes have actually been decided.
- Arguments built from your case, not a template. Draft positions are assembled from your own case details and public CMS outcome data, so every packet reflects the actual dispute.
- Hard rules stay hard. Deadlines, batch limits, duplicate checks and out-of-scope services are decided by fixed rule logic, not left to interpretation.

The pricing model is different, too. Much of the outsourced IDR help on the market charges a contingency: a percentage of whatever extra you recover. Published rates range from 10% of the improvement over the payer’s initial offer (Claims Assassins) to “20 percent or more” as described by one software competitor (Sydra). In a services agreement filed with the SEC, HaloMD, one of the largest IDR filers, charged a client 20% of the net recovery on federal IDR awards, while the client still paid the IDR entity and CMS administrative fees up front (SEC filing). A June 2026 amendment lowered that to 16% for awards issued on or after July 1, 2026 (amendment).
Using the worked example in that agreement (written for a state arbitration claim, but the math is the same), a $2,000 award less a $100 initial payment, $100 patient responsibility and a $115 administrative fee leaves a $1,685 net recovery. At 20%, the firm’s fee is $337. At 16%, it’s $269.60 (SEC filing). Across 100 similar wins, that’s $26,960 to $33,700, and it grows with every dollar you win. Government fees, by contrast, are modest: the $15 administrative fee per party, and a certified IDR entity fee of $200–$840 for a single determination that the losing party pays (CMS; CMS entity fee list).
IDR Insight AI is built to be priced as software, not as a cut of your recovery, so the upside of a win stays with the provider.

Feature highlights
- AI-drafted, paste-ready filings and evidence packets organized for the CMS IDR portal (CMS offers no public filing API, so you file in your own account and stay in control).
- Automatic deadline calculation in federal business days from your anchor date for open negotiation, IDR initiation, entity selection and offer submission.
- Built-in CMS and NUBC code sets: place of service, HCPCS codes and modifiers, bill types and revenue codes, plus CPT format checks.
- Date and price validation that catches problems before they become ineligibility findings.
- Forms that keep your work when a validation error appears.
- Batching and bulk import from CSV or Excel, with batch suggestions that follow federal rules.
- Case tracking for every open dispute, its status and its next deadline.
- Outcome insights from CMS public use files: historical win rates and typical prevailing offers relative to the QPA by service code, state and certified IDR entity.
Join the IDR Insight AI pilot
We’re looking for a few pilot partners to help us get IDR Insight AI up and running in real-world workflows. It’s a good fit if you’re an independent or specialty practice, a medical billing company or a revenue cycle management firm handling out-of-network claims.
What pilot partners get:
- Early access to IDR Insight AI before general release
- Hands-on onboarding and setup by our team
- Direct input on the product roadmap
- Founding-partner pricing, set together with us
What we ask in return:
- Real out-of-network dispute volume to run through the tool
- Honest, regular feedback on what works and what doesn’t
Ready to talk? Contact Nick Nguyen at ITS: call (949) 415-6975 or email its@NickNguyen.com. You can also request access at idr.internettechnologyservices.com.
Note: IDR Insight AI is a software tool, not legal advice. Consult qualified counsel about your specific disputes.
Sources: GAO-24-106335; CMS, Independent Dispute Resolution Reports; CMS, Supplemental Background on the Federal IDR PUF, July 1 – December 31, 2025; Georgetown CHIR, Aug. 2026; Medical Economics, Aug. 27, 2026; Holland & Hart, June 26, 2026; CMS IDR fee final rule fact sheet; CMS list of certified IDR entities; HaloMD–Nutex agreement (SEC); First Amendment to HaloMD–Nutex agreement; Claims Assassins; Sydra.






