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Who files Federal IDR disputes?

In 2025-Q4 the ten largest initiating parties or their representatives filed 67% of out-of-network emergency and non-emergency disputes. Practices with 50 or fewer employees were behind 37% of initiations.

Top initiating parties or their representatives

CMS lists the party or representative that submitted the dispute, which can be a billing company filing for many practices.

Party or representativeDisputes initiatedShare
HaloMD134,46719%
Team Health75,76211%
SCP Health50,4517%
F&A Management39,6836%
Radiology Partners36,3125%
M&D Capital Advisors35,7185%
QMACS, Inc.32,4935%
Radix32,3295%
US Anesthesia Partners17,1742%
Gottlieb & Greenspan16,8522%

By practice or facility size

Size2025-Q12025-Q22025-Q32025-Q4
Fewer than 20 Employees41,85847,34562,28577,900
20-50 Employees160,032213,156231,204184,975
51-100 Employees65,39967,24468,64968,454
101-500 Employees122,649110,393107,964107,506
Over 500 Employees53,15254,81658,46295,820
Unknown91,082137,876115,106172,846

Source: CMS Federal IDR Supplemental Tables, reporting year 2025 (CMS reports page). Quarterly medians cannot be combined into a yearly median, so each quarter is shown separately.

Many small practices appear to use a representative. Our fee calculator shows what a percentage arrangement costs against a flat fee.