Every year, insurance companies systematically underpay out-of-network physicians. Federal estimates of healthcare waste, fraud, and abuse exceed $500 billion annually (HHS Office of Inspector General)—and underpaid physician claims represent a significant share. Providers often do not realize they are being shortchanged, or lack the resources to fight back against the country's most powerful insurers.

The question is not whether your practice is losing money to insurance underpayments. The question is how much. This article will help you answer that with the published federal numbers, a calculator built on them, and the specialty-by-specialty medians the Departments actually report — so every input is one you can check against the source rather than take on trust.

$500B+
Healthcare Waste & Abuse (HHS OIG)
1.7–5.5×
Prevailing offer vs QPA, by claim size (CMS)
~85%
Decisions for Providers at IDR

The Billion-Dollar Problem Hiding in Your EOBs

When an out-of-network physician submits a claim, the insurer is supposed to pay a reasonable rate for the services rendered. In theory, this should reflect what other providers in the same geographic area charge for the same procedure. In practice, insurers use every trick available to minimize what they pay.

The most common tactic is manipulating the Qualifying Payment Amount (QPA)—the median contracted rate the insurer pays to in-network providers. But here is the problem: insurers set those contracted rates artificially low, then use them as the baseline for out-of-network reimbursement. The result is a benchmark derived from the plan's own contracts, applied to a physician who never signed one. Whether that benchmark is defensible is precisely the question federal arbitration exists to answer — and in 2024 the certified entities answered it in the provider's favour in about 85% of the determinations they made.

How big is the gap? The Departments publish the only measurement that is not an estimate. Where a dispute reached a determination, the median prevailing offer stood at 5.53× the QPA on claims under $100, 3.45× between $100 and $500, and 1.73× at $10,000 and above. Those multiples are the distance between what the plan calculated and what an independent entity found defensible — measured across hundreds of thousands of decisions rather than inferred from a sample.

One correction worth making, because it changes who you are actually arguing with: in most of these disputes the money does not belong to the insurer. Self-funded and partly self-funded employer plans accounted for 320,845 of the 478,849 disputes initiated in the fourth quarter of 2024 (CMS Federal IDR Supplemental Tables, Q4 2024, Table 3). The carrier is administering someone else's money, which is also why a state insurance law usually cannot reach the claim.

The No Surprises Act, signed on 27 December 2020 and effective from 1 January 2022, created a federal Independent Dispute Resolution process built for exactly this imbalance. In 2024 the provider side prevailed in about 85% of payment determinations — determinations, not disputes filed, since roughly 19% were found ineligible — and the median prevailing offer stood above the plan's own benchmark in every cost band CMS reports, from 5.53× QPA on claims under $100 to 1.73× at $10,000 and above.

Interactive Revenue Recovery Calculator

Use our detailed calculator below to estimate your practice's potential annual recovery. Enter your specialty, volume of out-of-network procedures, average billed amounts, and typical underpayment rates to see what you could be recovering through IDR arbitration.

Revenue Recovery Calculator

Calculate Your Practice's Recovery Potential

Three inputs are yours; the rest are published CMS figures, shown in the formula below the result.

Per provider — multiply below if you are a group
The insurer's own benchmark, shown on your EOB — not your billed charge
Physicians in your group
Modelled recovery above QPA, per year
$205,229
Gross, before our contingency percentage and IDR entity fees
Determinations expected to go your way
248
Modelled gap closed per successful claim
$828

The formula: your claims × 12 × 81% eligible × 85% decided for providers × your QPA × (specialty multiple − 1). The three fixed factors are published CMS figures for 2024, not our estimates — sources here. This is a scenario built from federal medians, not a prediction: your eligibility, timing, documentation and payer mix move every number in it. Send us your EOBs and we will work it through on your actual claims.

Recovery Breakdown by Medical Specialty

Not all specialties face the same picture, and CMS measures the difference directly: Table 14 of the Departments' supplemental tables reports the median prevailing offer as a share of the plan's qualifying payment amount, broken out by CPT category. Below is that table for the second half of 2024, with the number of determinations behind each figure.

Median prevailing offer as a share of QPA, by specialty (CMS Table 14)
Specialty CPT range Q4 2024 Q3 2024 Determinations, H2 2024
Emergency Medicine 99281–99288 3.07× 2.88× 281,728
Radiology 70010–79999 5.11× 5.59× 138,490
Neurology & Neurodiagnostics 95700–96020 16.75× 14.96× 54,449
Surgery 10004–69990 13.02× 10.42× 54,174
Anesthesiology 00100–01999 3.31× 2.28× 48,109
Pathology & Laboratory 80047–89398 4.13× 3.15× 14,424
Critical Care 99291–99292 3.22× 3.04× 15,211
Air Ambulance 2.26× 2.39× 19,145

Emergency Medicine: The Volume Play

Emergency medicine is the largest category in federal arbitration, and the reason is structural rather than clinical: a patient in extremis does not choose a network, so the physician and the plan end up opposite each other with the patient protected in between. In the fourth quarter of 2024 alone, certified IDR entities issued 154,987 payment determinations in this category.

The median prevailing offer in emergency department disputes ran 3.07× the plan's qualifying payment amount in that quarter, up from 2.88× the quarter before. That is a lower multiple than several smaller specialties — emergency medicine's opportunity is in the count, not the per-claim gap, which is exactly what makes batching decisive here.

Neurodiagnostics: The Widest Measured Gap

The category CMS labels neurology and neuromuscular procedures carries the highest median in the entire dataset: 16.75× QPA in the fourth quarter of 2024, across 54,449 determinations in the half-year. In practice this category is dominated by intraoperative neuromonitoring — performed during a surgery the patient consented to, by someone the patient never selected, often supervised remotely.

A high median does not make any individual claim likely to succeed. What it does say is that where these disputes reached a decision, the distance between the plan's benchmark and what an independent entity found defensible was larger than anywhere else measured.

Surgery and Radiology

Surgery ran 13.02× in the fourth quarter of 2024 across 54,174 determinations in the half-year, and radiology 5.11× across 138,490 — the second-largest category by volume after emergency medicine. Radiology is the clearest illustration of why claim size matters more than specialty: it combines high volume with modest per-claim values, and CMS's cost-band table shows the largest multiples sitting on the smallest claims (5.53× below $100, against 1.73× above $10,000).

Anesthesiology and Pathology

Anesthesia ran 3.31× and pathology and laboratory 4.13×. Both are ancillary services under the No Surprises Act, meaning balance billing is prohibited and the consent exception is unavailable — federal IDR is the only route left when the payment is disputed. Anesthesia adds a wrinkle no other specialty has: because it is billed in base and time units against a conversion factor, how the plan derived that factor is frequently the substance of the dispute.

The full table, every category CMS reports, is here.

Run It Against Your Own Claims

We analyse your own EOBs, payer mix and claim history and tell you what is eligible, what the timing looks like, and whether the arithmetic works. If it does not, we say so.

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What the Published Medians Say Your Claims Are Worth

You will find case studies on most sites in this business: a practice name, a recovered amount, a win rate. We have taken ours down. You cannot verify them, we cannot substantiate them to the standard the FTC applies to that kind of claim, and a number you cannot check is worth nothing to you when you are deciding whether to spend your time on this.

Here is what you can check instead. CMS publishes the outcome of every federal IDR determination in aggregate, and three of those published figures are all you need to size the opportunity.

  • About 19% of disputes initiated in 2024 were found ineligible — so roughly four in five reach a determination.
  • Of determinations made, the provider side prevailed in about 85%.
  • The median prevailing offer, expressed against the plan's own qualifying payment amount, ran from 5.53× on claims under $100 down to 1.73× on claims of $10,000 and above.

Multiply them: for every 100 claims you could dispute, about 81 reach a decision, about 69 of those go your way, and each of those closes the gap between what the plan paid and the median multiple for that claim size. Take a $400 average QPA as an illustration — substitute your own — in the emergency department category, where the published median ran 3.07×, that is roughly $828 per successful claim above what the plan paid.

That arithmetic is the whole model. It uses no assumption we invented, and you can substitute your own claim volume and your own QPAs in about a minute. Every figure in it, with the CMS source.

What it deliberately does not tell you is what your practice will recover. That depends on your eligibility, your documentation, your timing and your payer mix — and the first of those is where most disputes are actually lost.

Which Plans Show Up Most Often in Federal Arbitration

CMS also publishes which parties appear most frequently on the other side of these disputes. This is a volume count, published by the government, and it says nothing about whether any of those parties did anything wrong — but it does tell you who is in the room.

Most frequently disputed parties, out-of-network items and services, second half of 2024 (CMS Table 9)
Non-initiating party or representative Disputes Share involving self-funded plans
UnitedHealthcare242,71174%
Aetna120,94369%
BCBS Texas119,11173%
MultiPlan96,78770%
Anthem65,16648%

The third column is the one that changes what you do. ERISA preempts state regulation of self-funded employer plans, so a state surprise-billing law generally cannot reach them — those disputes belong in the federal process even in states that run their own. The full table, including the vendors that appear as plan representatives, is here.

The Compounding Cost of Inaction

Perhaps the most insidious aspect of insurance underpayments is how they compound over time. Every month your practice does not pursue recovery, another layer of lost revenue accumulates. And with statutes of limitations typically running 3 to 4 years depending on the state and payer type, older claims eventually become permanently unrecoverable.

Consider a mid-sized practice losing $100,000 per month to underpayments. Here is what inaction looks like over time:

After 6 Months $600,000 lost
$600K
After 1 Year $1,200,000 lost
$1.2M
After 2 Years $2,400,000 lost
$2.4M
After 3 Years (Approaching SOL) $3,600,000 lost — claims expiring
$3.6M — EXPIRING

The compounding effect is not just about the total dollar amount. It is about the window of opportunity closing. The federal clock does not run from the date of service — it runs from each payment or denial: 30 business days of open negotiation, then a four-business-day window to initiate. Miss that window on a given claim and it is gone regardless of the case for recovery might be.

Even practices that eventually decide to pursue recovery often discover that their oldest and often most valuable claims have already expired. The cost of waiting another six months is not just another $600,000 in new losses; it is the permanent loss of $600,000 in older claims that have now aged past the statute of limitations.

DIY Recovery vs. Professional Recovery Service: The ROI Comparison

Many practices wonder whether they can handle insurance recovery in-house. After all, if the process is just about filing IDR claims, why not do it yourself and keep 100% of the recovery? The answer comes down to expertise, volume, and realistic recovery rates.

DIY In-House Recovery

Hiring staff and managing the process internally.

  • Requires dedicated staff time, and the cost of that time falls on the practice whether or not a given dispute succeeds
  • The eligibility, batching and timing rules have to be learned somewhere, and on live claims the tuition is paid in claims that die on a technicality
  • The published national figure — about 85% of determinations going to providers — describes disputes that were eligible and correctly filed, not disputes in general
  • Eligibility, deadlines and batching have to be learned somewhere, and the tuition is paid in dead claims
  • Must develop QPA challenge strategies from scratch
  • Administrative burden on physicians and practice management
  • CMS publishes the ineligibility rate (~19% in 2024) but not a breakdown of causes — what it does publish is that eligibility was challenged in a large share of disputes, which is where the scrutiny falls
Recommended
Professional Recovery Service

Contingency-based, zero upfront cost model.

  • Zero upfront investment—contingency fee only on amounts recovered
  • No ramp-up on the eligibility and timing rules, which is where the 19% national ineligibility rate is created
  • Eligibility screened before anything is filed, so the fee is not spent on claims that cannot be heard at all
  • Submissions built around the factors the statute directs a certified IDR entity to weigh
  • QPA challenges documented against independent rate evidence
  • Zero administrative burden on your practice
  • Contingency fee, stated as a percentage in writing before any filing

The Honest Version of That Comparison

We are not going to publish a table showing that using us returns twice what doing it yourself returns. We would be making both numbers up, and you would have no way to test either.

What is true and checkable: the process is documentary, the deadlines are short and unforgiving, and roughly one in five disputes initiated nationally in 2024 never reached a decision because it was found ineligible. A practice that files carefully and on time can do this itself — several of the largest filers in the CMS tables are provider groups doing exactly that. What a practice cannot do is learn the eligibility rules on its own live claims without losing some of them, because a claim rejected on timing does not come back.

Our contingency percentage is stated in writing before anything is filed, and it comes out of what is actually recovered. If a set of claims does not clear the eligibility and timing tests, we say so and nothing is filed — that is the case where doing nothing is the right answer, and we would rather tell you than bill you for finding out.

How to Get Started: Your Recovery Roadmap

If the numbers in this article resonate with your practice's experience, the path forward is straightforward:

  1. Request a free revenue analysis. We review your EOBs, payer mix and claim history to tell you what is eligible, what the deadlines are, and what the published medians imply — not a generic projection, but a case-by-case assessment based on your actual data. Start your free analysis here.
  2. Review the findings. You receive a written report setting out which claims clear eligibility, which deadlines apply to each, what the federal medians imply for them, and the recommended filing strategy.
  3. Approve and we begin. With your approval, we prepare and submit the disputes through the federal portal. There is no upfront cost and no retainer, and our fee comes only out of what is recovered. There is one real cost the process itself carries, and we would rather you hear it from us: the certified IDR entity fee falls on the non-prevailing party. We are paid a contingency fee only on amounts we successfully recover.
  4. Collect your recovery. As IDR decisions come in and payments are collected, funds are deposited directly into your practice accounts. The statute sets the pace: 30 business days of negotiation, 4 to initiate, 30 for the determination, and payment due within 30 calendar days of it.

The No Surprises Act IDR process was designed to rebalance the power dynamic between insurers and providers. But the process only works if you use it. Every month of inaction is another month of revenue permanently lost.

Stop Leaving Money on the Table

The federal process is being used at scale — 1,371,862 disputes closed in 2024 alone. Whether any of your claims belong in it is a question about your eligibility and your deadlines, and the review that answers it costs nothing.

Get My Free Recovery Analysis

Frequently Asked Questions

How far back can we recover underpayments?

The federal IDR process under the No Surprises Act applies to claims from January 1, 2022 onward. Some state laws and ERISA appeal pathways may allow recovery on even older claims, depending on the payer and plan type. How far back your own claims reach depends on the route: federal IDR reaches nothing before 1 January 2022, while an employer plan's appeal deadlines are set by the plan document.

Is there really zero upfront cost?

Yes. Professional recovery services work on a contingency basis. You pay us nothing unless and until underpayments are recovered. The federal process charges separately — $15 per party per dispute, and the certified IDR entity fee on the non-prevailing party. That aligns the incentives, though it does not make the process free of cost in every case: the federal administrative fee is $15 per party per dispute, and the certified IDR entity's fee falls on the non-prevailing party.

How long does the IDR process take?

From initial filing to determination, the statute gives the certified IDR entity 30 business days from selection, and payment due within 30 calendar days of the determination. Add those together — roughly six weeks of negotiation, the four-business-day window, then up to thirty business days for the determination, then thirty calendar days for payment — and the earliest money can realistically arrive is about four months after the negotiation notice goes out — sooner is not possible, and slower is common where eligibility is challenged. Learn more in our complete guide to No Surprises Act arbitration.

Will pursuing IDR damage our insurer relationships?

No. The IDR process is a federally established right. Thousands of providers use it routinely, and insurers expect it as part of normal business operations. Whether a plan adjusts its behaviour after a run of adverse determinations is not something anyone has measured publicly, so treat claims to that effect — including ours — as speculation rather than a reason to file.

What if our claims are small? Is it still worth pursuing?

The IDR process includes a batched filing option that allows multiple similar claims to be submitted together, reducing per-claim costs. Even practices with relatively small individual claim amounts can achieve significant aggregate recoveries when claims are batched strategically.

This article is for informational purposes only and does not constitute legal, financial, or medical billing advice. Consult a qualified professional for guidance specific to your situation.