Ripplarity Inc · IDRGateKit

How each certified IDR entity ruled, July–December 2025

A neutral read of the CMS Federal No Surprises Act Independent Dispute Resolution public-use files: outcomes by certified entity, state and service code, covering 2025-Q3,2025-Q4.

Sold on identical terms to providers, payers, law firms and analysts; this report takes no position.

Per certified IDR entity

Sorted by volume of decided disputes. "Prevailing %" is the share of disputes decided for the provider, weighted by dispute count (n) across every published (state, service code) cell for that entity. Offer percentages are the entity's weighted median offer as a percentage of the qualifying payment amount (QPA) — 100% means the offer equalled QPA.

Read the spread carefully. These are raw rates, not adjusted for case mix. Disputes are not assigned to entities at random: the states, specialties and service codes each entity receives differ, and those differences alone can move a prevailing rate. A gap between two entities therefore shows what happened in the disputes each one decided; it does not by itself show that one entity rules differently from another on like cases. Offer figures are weighted medians of per-cell medians, because the public file is aggregated here before publication; they are close to, but not identical with, a true population median.

Disclosure. Ripplarity Inc d/b/a Trilatic has applied to become a certified IDR entity. This report is computed from CMS's public file by a script published with it, and would read identically had the application not been made; we state the application so that no reader has to discover it.

Consistency with independent analyses. Milliman's August 2026 brief, using CMS data through 2025 Q2, reports provider offers typically at 276% to 799% of QPA and plan offers at 100% to 138%; the published cells here fall inside those ranges. Milliman also notes that entity-level outcome data was not available through 2025 Q2 and that "it is unclear what information and data IDREs have been using to resolve disputes." The 2025 Q3–Q4 file is the first in which CMS names the deciding entity, which is what makes the per-entity figures above possible.

Federal Hearings and Appeals 81.4% C2C Innovative Solutions, In 89.4% Island Peer Review Organizat 96.1% Provider Resources, Inc. 95.2% MCMC Services, LLC 91.5% EdiPhy Advisors, L.L.C. 90.4% Maximus Federal Services, In 90.7% Network Medical Review Compa 69.2% iMPROve Health 86.6% National Medical Reviews, In 70.9% Medical Evaluators of Texas 57.7% Keystone Peer Review Organiz 79.6% ProPeer Resources, LLC 55.1% Capitol Bridge, LLC 60.0% Livanta (DBA:Commence) 64.1%
Certified IDR entityDisputes decidedShare of all decidedProvider prevailing %Median provider offer % of QPAMedian payer offer % of QPA
Federal Hearings and Appeals Services, Inc.866,78831.7%81.4%670%100%
C2C Innovative Solutions, Inc.352,74412.9%89.4%401%100%
Island Peer Review Organization258,3439.4%96.1%519%120%
Provider Resources, Inc.257,3399.4%95.2%444%100%
MCMC Services, LLC173,6716.3%91.5%431%100%
EdiPhy Advisors, L.L.C.158,1045.8%90.4%607%100%
Maximus Federal Services, Inc.132,9154.9%90.7%783%110%
Network Medical Review Company, Ltd.125,6584.6%69.2%449%105%
iMPROve Health124,7144.6%86.6%349%115%
National Medical Reviews, Inc.100,2893.7%70.9%323%105%
Medical Evaluators of Texas68,2912.5%57.7%331%100%
Keystone Peer Review Organization, Inc.50,1141.8%79.6%462%100%
ProPeer Resources, LLC42,8461.6%55.1%377%113%
Capitol Bridge, LLC12,1210.4%60.0%565%100%
Livanta (DBA:Commence)11,4070.4%64.1%381%111%

The spread between entities

Island Peer Review Organization has the highest provider-prevailing rate among entities with at least 1,000 decided disputes, at 96.1%. ProPeer Resources, LLC has the lowest, at 55.1%. That is a gap of 41.0 percentage points between 15 entities meeting the volume threshold.

Top 10 states by volume

Provider prevailing % is weighted by dispute count across all published service-code cells in that state.

TX 84.2% AZ 82.9% FL 87.8% CA 88.3% TN 82.5% GA 86.8% NJ 86.1% NY 87.3% OK 92.7% IN 87.3%
StateDisputes decidedProvider prevailing %Entity deciding the most disputes there
TX1,356,68084.2%Federal Hearings and Appeals Services, Inc.
AZ173,14282.9%Federal Hearings and Appeals Services, Inc.
FL162,85287.8%Federal Hearings and Appeals Services, Inc.
CA115,24388.3%Federal Hearings and Appeals Services, Inc.
TN95,73382.5%C2C Innovative Solutions, Inc.
GA86,21886.8%Federal Hearings and Appeals Services, Inc.
NJ61,92386.1%Maximus Federal Services, Inc.
NY60,11587.3%Federal Hearings and Appeals Services, Inc.
OK59,21192.7%Island Peer Review Organization
IN55,55187.3%Federal Hearings and Appeals Services, Inc.

Top 15 service codes by volume

Service codeDisputes decidedProvider prevailing %Median provider offer % of QPA
99284514,40284.6%412%
99285297,16785.8%323%
99283149,10781.5%537%
8502555,75483.6%511%
7104546,13388.6%427%
8005345,75984.3%586%
7417741,81587.3%730%
9929138,59186.9%360%
7104631,64685.9%853%
9637531,54785.6%745%
8100329,46281.7%891%
7045029,06788.4%575%
7706727,46993.2%308%
9636127,11285.1%519%
9637427,11084.5%568%

Coverage and method

Quarters covered: 2025-Q3,2025-Q4. Total dispute line items in the underlying CMS release: 3,007,933. Of 134,143 (state, service code, certified IDR entity) cells built from that release, 111,218 are suppressed because they cover fewer than 11 disputes and publish no rate or offer figures — only 22,925 cells, covering 2,735,344 disputes, are published and used in every figure above. Certified IDR entity names come from CMS's own reporting field, first published starting with the 2025 Q3 release.

Centers for Medicare & Medicaid Services. (2025). Federal IDR Public Use File [Data file and data dictionary]. Retrieved from https://www.cms.gov/nosurprises/policies-and-resources/reports Data in the Federal IDR PUF reflect data captured in the Federal IDR portal as of the date of the report; CMS does not guarantee the accuracy of all records and all fields. In particular, the QPA field was self-reported by the initiating party and was not necessarily verified by the health plan or issuer -- see CMS's disclaimer PDF above for the full QPA caveat before relying on offer-as-%-of-QPA figures for anything load-bearing.

Generated by scripts/build_idr_report.py from IDRGateKit's benchmarks.sqlite3 artifact. Every number on this page is computed by that script from published cells (suppressed=0), weighted by dispute count (n).

Cite this

Ripplarity Inc / IDRGateKit. “How each certified IDR entity ruled, July–December 2025.” https://www.ripplarity.com/idr-entity-report-2025-h2.html Source data: Centers for Medicare & Medicaid Services, Federal IDR Public Use File, 2025 Q3–Q4. Retrieved and computed 2025-Q3,2025-Q4. Accessed via https://idrgatekit-udrj5akpma-uc.a.run.app/benchmarks.

Full benchmarks data product, with state and service-code drill-down beyond the top 10/15 shown here: https://idrgatekit-udrj5akpma-uc.a.run.app/benchmarks.