Federal IDR guides
When should you not file for federal IDR?
Three cases where filing is the wrong call, the math for everything else, and why the answer changes once the cost per dispute drops.
Verified September 11, 2026
Short answer
Do not file when the payer already paid close to what you would win. Do not file when you have no process and the claim is small, because the hours will eat the gain. Do not file when a small team's time is worth more on something else.
Past that, work out each claim on its own numbers. With an 86% win rate and a $15 CMS fee, the bar is low. The thing that keeps most groups from filing is not the math. It is the work.
CMS fee
$15
Per side, since June 11, 2026
Entity fee at risk
$498
Median recorded, single dispute
Provider win rate
86%
Decided lines, 2025
Batch cap
50 lines
From November 1, 2026
Three cases where you should not file
| Case | Why | What to do instead |
|---|---|---|
| The payment is already close to your number | You can win and still net less than the fees and time | Accept, or negotiate without filing |
| No process, small claim | A hand-built dispute costs hours. On a $300 gap that is a loss even when you win | Batch it, or hold it until you have a process |
| Your team's time is worth more elsewhere | A three-person billing office filing IDR is not doing follow-up, appeals, or posting | Outsource the filing, or file only the big ones |
The math for everything else
What you risk on a single claim is the IDR entity fee, around $498, plus $15 to CMS, plus the hours. Win and the entity fee comes back. The $15 never does.
What you stand to gain is not the gap between the two offers. IDR sets the total the plan owes for that service. What reaches you is that total minus what the payer already paid and minus the patient's cost sharing. If the award lands below what was already paid, you send money back. So the figure to weigh is the extra payment, after fees and after the work.
In 2025 the winning offer was 399% of the QPA at the median. Among decided lines where the files record a payer offer against the QPA, 54% were at or below it.
Batching moves this more than anything else, because one fee covers the whole batch. From November 1, 2026, a batch is capped at 50 lines.
The June 2026 fee cut moved the line
Until June 10, 2026 the CMS fee was $115 per side. It is now $15. That took about $100 off the cost of every dispute. Claims that were not worth filing at $115 are worth filing now, if filing them is cheap.
The bigger question is not one claim
Most groups weigh one claim at a time and stop there. That is why they file so few. The other question is which part of your claim curve clears the bar at your cost per dispute.
If a dispute costs you three hours of staff time, only the biggest claims clear. If it costs a few minutes, most of them do. The claims themselves have not changed. The cost of filing has.
Recourse
Where Recourse fits
Recourse takes the whole curve, checks each claim for eligibility, and files what the data says is worth filing. Our fee is a share of what comes back, so we do not file claims that do not pay.
Sources
CMS notice, "IDR Administrative Fee Update," June 3, 2026; CMS Federal IDR Guidance for Disputing Parties, section 8.2; CMS notice, "Changes to Batching Disputes," August 3, 2026; CMS Federal IDR Public Use Files, 2025 Q1 to Q4, line level, air ambulance excluded, deduplicated to the latest quarterly record. Win rate is provider offer selected over decided lines. The fee figure is the median compensation recorded on single disputes where a positive amount was recorded.
Every number on this page comes from public CMS files or the federal rule. Our methodology explains how we count. Questions? sales@recoursehealth.com
Your data, not the national average
See how your group's IDR record compares.
A free report card built from the same CMS files, measured at the group level. Nothing needed from you.