Federal IDR in Texas
Texas 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 Texas.
2025 Q1–Q4 · State = Location of Service
Claim lines
2,535,967
44% of all US claim lines
Decided lines
2,349,738
Across 869,943 disputes
Provider win rate
86.7%
Defaults count as losses
Median prevailing offer
480%
Of QPA
560% of QPA median provider offer.
1.9% default-loss share of lines.
32 days median time to determination.
Applicability
Does Texas law or federal IDR apply?
Texas has its own surprise-billing law, Senate Bill 1264, with state mediation and arbitration processes for certain claims involving state-regulated plans. The Texas Department of Insurance states that the law applies to state-regulated coverage and does not generally apply to self-funded employer-sponsored plans.
Federal protections and the federal IDR process can apply when Texas law does not govern the plan or claim, including many self-funded ERISA plans and other federally regulated coverage. The correct path depends on plan type, service, provider, facility, and claim facts.
See how your group's IDR outcomes compareTexas 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 | 433,531 | 423,462 | 87.6% |
| 2025 Q2 | 718,009 | 671,708 | 89.2% |
| 2025 Q3 | 719,391 | 661,329 | 88.6% |
| 2025 Q4 | 665,036 | 593,239 | 81.2% |
Payers with the most Texas claim lines
| Payer | Lines | Provider win rate | Median prevailing / QPA | Default-loss share |
|---|---|---|---|---|
| Blue Cross Blue Shield of Texas | 1,160,595 | 87.9% | 592% | 1.6% |
| Aetna | 473,916 | 93.3% | 452% | 0.9% |
| UnitedHealthcare | 394,682 | 83.1% | 485% | 2.5% |
| MultiPlan | 253,601 | 79.4% | 451% | 3.0% |
| ClearHealth Strategies | 104,548 | 82.7% | 308% | 1.5% |
| BCBS Illinois | 35,569 | 80.9% | 100% | 10.3% |
| Cigna | 10,876 | 87.3% | 510% | 3.3% |
| Centene | 9,810 | 88.8% | 225% | 8.2% |
Certified IDR entities in the Texas 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 |
|---|---|---|
| Federal Hearings and Appeals Services | 554,603 | 78.8% |
| C2C Innovative Solutions | 178,721 | 91.3% |
| Island Peer Review Organization | 141,703 | 97.8% |
| Provider Resources | 133,459 | 97.2% |
| MCMC Services | 71,438 | 91.2% |
| EdiPhy Advisors | 67,196 | 93.8% |
| Network Medical Review | 61,360 | 68.1% |
| Maximus Federal Services | 41,919 | 91.9% |
Specialty mix
The supplied analysis groups usable specialty labels into six provider categories. The unknown bucket is omitted.
| Specialty | Lines | Provider win rate |
|---|---|---|
| Emergency | 1,538,409 | 85.1% |
| Radiology | 516,148 | 95.0% |
| Hospital medicine | 86,308 | 89.3% |
| Anesthesia | 79,362 | 86.8% |
| Neuromonitoring | 57,798 | 89.2% |
| Surgery | 29,959 | 88.7% |
What the Texas data shows
Texas accounts for 44% of all US claim lines in the supplied 2025 analysis. That concentration makes payer, specialty, and certified IDR entity mix especially important when interpreting the statewide totals.
The payer table spans materially different win rates, prevailing-offer levels, and default-loss shares. The certified IDR entity table also shows a wide range of provider offer selection rates in the named Q3 and Q4 records. These are descriptive aggregates, not controlled comparisons of payer or entity performance.
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 Texas 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.