Federal IDR in Tennessee
Tennessee 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 Tennessee.
2025 Q1–Q4 · State = Location of Service
Claim lines
231,351
Across 72,486 disputes
Decided lines
227,457
No-decision lines excluded
Provider win rate
83.8%
Defaults count as losses
Median prevailing offer
284%
Of QPA, uncapped median
331% of QPA median provider offer.
2.7% default-loss share of lines.
43 days median time to determination.
Applicability
Does Tennessee law or federal IDR apply?
Tennessee has state balance-billing provisions in limited settings, but the Tennessee Department of Commerce and Insurance's No Surprises Act guidance relies on the federal framework for the broad surprise-billing protections and payment disputes covered here. This draft does not treat Tennessee as having a broad specified state payment law that replaces federal IDR for these claims.
Federal IDR applies to eligible claims under covered plans when no specified state law controls. The correct path depends on plan type, service, facility, provider, and claim facts.
Tennessee 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.
| Closing quarter | Lines | Decided lines | Provider win rate |
|---|---|---|---|
| 2025 Q1 | 52,952 | 52,950 | 86.3% |
| 2025 Q2 | 70,105 | 69,534 | 84.5% |
| 2025 Q3 | 61,363 | 59,921 | 82.9% |
| 2025 Q4 | 46,931 | 45,052 | 81.0% |
Payers with the most Tennessee claim lines
| Payer | Lines | Provider win rate | Median prevailing / QPA | Default-loss share |
|---|---|---|---|---|
| UnitedHealthcare | 86,350 | 87.0% | 269% | 1.6% |
| Cigna | 71,072 | 82.0% | 301% | 2.8% |
| MultiPlan | 24,381 | 76.5% | 335% | 5.8% |
| BCBS Tennessee | 11,531 | 68.4% | 253% | 6.8% |
| ClearHealth Strategies | 11,285 | 84.8% | 241% | 2.5% |
| Centene | 9,882 | 94.9% | 327% | 2.0% |
| Zelis | 6,162 | 93.7% | 360% | 0.3% |
| Clear Health (cloud) | 3,503 | 87.9% | 207% | 0.5% |
Certified IDR entities in the Tennessee 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.
| Certified IDR entity | Lines | Provider win rate |
|---|---|---|
| C2C Innovative Solutions, Inc. | 27,165 | 86.6% |
| iMPROve Health | 11,147 | 88.7% |
| Federal Hearings and Appeals Services, Inc. | 8,392 | 86.8% |
| MCMC Services, LLC | 8,267 | 90.3% |
| Provider Resources, Inc. | 8,173 | 93.1% |
| Network Medical Review Company, Ltd. | 7,028 | 68.7% |
| Maximus Federal Services, Inc. | 6,523 | 86.5% |
| National Medical Reviews, Inc. | 6,221 | 76.1% |
Specialty mix
The supplied analysis groups usable specialty labels into provider categories. The unknown bucket is omitted.
| Specialty | Lines | Provider win rate |
|---|---|---|
| Hospital medicine | 101,721 | 86.4% |
| Emergency | 87,400 | 82.9% |
| Anesthesia | 18,314 | 88.2% |
| Neuromonitoring | 6,114 | 81.5% |
| Pediatrics | 4,880 | 87.2% |
| Other | 2,749 | 70.1% |
What the Tennessee data shows
Hospital medicine is the largest supplied Tennessee specialty group, followed by emergency services. UnitedHealthcare and Cigna together account for most of the listed payer lines, while the remaining payer rows carry different prevailing-offer medians and default-loss shares.
The named Q3 and Q4 certified IDR entity results also span distinct provider win rates. Tennessee's statewide figure is therefore a blend of different payer, specialty, and entity populations rather than one uniform outcome.
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 Tennessee claims
See how your group's IDR outcomes compare.
Request a free per-group report card using the same 2025 CMS methodology shown on this page.