Federal IDR in California

California surprise billing law and federal IDR

See which dispute path may apply, then examine 2025 federal IDR volume, provider offer selection, payer outcomes, certified IDR entity mix, and specialties for services delivered in California.

2025 Q1–Q4 · State = Location of Service

Claim lines

209,891

Across 69,665 disputes

Decided lines

205,718

No-decision lines excluded

Provider win rate

88.5%

Defaults count as losses

Median prevailing offer

263%

Of QPA, uncapped median

289% of QPA median provider offer.

0.9% default-loss share of lines.

36 days median time to determination.

Applicability

Does California law or federal IDR apply?

California has state surprise-billing protections and payment rules, including AB 72 for specified nonemergency services provided by noncontracted providers at contracted facilities. Those rules apply where California law governs a state-regulated plan and the claim falls within the state law.

Federal protections and federal IDR can apply when California's specified state law does not control, including many self-funded employer plans and other federally regulated coverage. The correct path depends on plan type, service, facility, provider, and claim facts.

See how your group's IDR outcomes compare

California outcomes by closing quarter

The quarter is the quarter in which a dispute closed. These figures are descriptive snapshots. They do not establish a directional pattern because CMS publishes in arrears and can restate records.

California federal IDR outcomes by 2025 closing quarter
Closing quarterLinesDecided linesProvider win rate
2025 Q126,50826,49289.5%
2025 Q248,87648,84890.3%
2025 Q372,67071,57388.1%
2025 Q461,83758,80587.2%

Payers with the most California claim lines

California federal IDR outcomes by payer
PayerLinesProvider win rateMedian prevailing / QPADefault-loss share
Anthem83,62190.4%349%0.8%
Aetna25,97893.7%248%0.3%
Cigna25,82284.3%226%3.0%
MultiPlan22,52984.0%190%0.1%
Blue Shield of California17,75383.0%574%0.7%
UnitedHealthcare13,50587.4%297%0.7%
ClearHealth Strategies2,71088.5%314%0.3%
Clear Health (cloud)2,25488.0%209%0.1%

Certified IDR entities in the California data

CMS added the named certified IDR entity field beginning with the 2025 Q3 file. This table therefore covers named Q3 and Q4 records only and should not be compared with the full-year state totals.

Named certified IDR entities in California, 2025 Q3 and Q4
Certified IDR entityLinesProvider win rate
Federal Hearings and Appeals Services, Inc.37,48486.4%
Maximus Federal Services, Inc.11,01992.1%
Network Medical Review Company, Ltd.9,64982.5%
EdiPhy Advisors, L.L.C.9,63198.1%
C2C Innovative Solutions, Inc.9,10891.8%
National Medical Reviews, Inc.8,65085.0%
iMPROve Health8,64891.6%
Provider Resources, Inc.8,10192.8%

Specialty mix

The supplied analysis groups usable specialty labels into provider categories. The unknown bucket is omitted.

California claim lines and provider win rate by specialty
SpecialtyLinesProvider win rate
Hospital medicine117,15689.2%
Emergency57,99389.8%
Surgery10,51387.7%
Other6,44489.4%
Neuromonitoring4,85587.4%
Anesthesia2,24681.0%

What the California data shows

Hospital medicine accounts for more than half of the supplied California claim lines, and Anthem is the largest listed payer. The statewide totals therefore reflect a concentrated specialty and payer mix rather than an even cross-section of all claims.

The payer rows show different prevailing-offer medians and provider win rates, while the named Q3 and Q4 entity results occupy a narrower but still distinct range. These descriptive aggregates do not isolate the effect of payer, specialty, service, or certified IDR entity.

A provider group's own result can differ because its payer mix, specialty, services, offers, defaults, and filing operations differ from the statewide population. The report-card CTA below applies the same measurement framework to the group's own claims.

Methodology, sources, and limits

This page uses all four 2025 CMS Federal IDR PUF files for OON emergency and non-emergency items and services. Air ambulance is excluded. Lines are deduplicated to the latest quarterly record. State is the Location of Service field.

Win rate is the share of decided lines where the provider offer was selected. Lines with no decision are excluded from both numerator and denominator. Default decisions count as losses and are also shown separately. Disputes are dated by closing quarter.

Provider-offer and prevailing-offer figures are uncapped medians of the respective offer as a percentage of QPA. Values are printed as computed, including unusually high medians. They are not rounded away or adjusted.

Source: CMS Federal IDR Public Use Files, 2025 Q1 through Q4. Q1 and Q2 data as of January 21, 2026; Q3 and Q4 published July 15, 2026. Full calculation rules: Recourse methodology.

Your California claims

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