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Anthem in Federal IDR Disputes

Anthem appears as the non-initiating party in 112,804 disputes. Its profile is unlike any other in Table 9: 56% self-funded, but 33% state and local government plans — the largest such share of any party in the table.

The Published Count

What CMS Reports

112,804
Disputes with Anthem as non-initiating party, H2 2025
#5
Rank among the ten most disputed parties
56%
Of those disputes involved self-funded plans
3,731
Disputes where the plan type was never established
Disputes involving Anthem by plan type, the second half of 2025
Plan typeDisputesShareWhich process it points to
Self-funded or partly self-funded employer plan62,94556%Federal — ERISA preempts state regulation
Fully insured group plan5,4625%A state process may apply
Individual market1800%Depends on the state
Federal Employees Health Benefits carrier3,4383%Federal
Non-federal government plan (state or local)37,04533%Depends on the state — not an ERISA plan
Church plan30%Depends on the state — not an ERISA plan
No issuer response3,7313%Plan type not established
All plan types112,804100%

Source: CMS, Federal IDR Supplemental Tables, Q3 and Q4 2025, Table 9 — “Top 10 Non-Initiating Parties”. “Non-initiating party” is the Departments' own term for the party a dispute is brought against; it carries no finding about conduct, and the counts measure volume of disputes rather than anything else. CMS publishes these tables here.

What It Means for Your Claim

Federal Process or State Process

That government share is the point. ERISA does not reach plans of state and local governments, so the reasoning that settles the route for self-funded employer plans does not carry over to them: for the 33% of Anthem disputes in that category, whether a state process applies depends on the state's own law and whether it reaches government plans. The 56% self-funded share goes federal under ERISA preemption regardless of the state. Fully insured plans are only 5%, and FEHB carriers 3%. With Anthem more than with any other party in the table, the plan type has to be established per claim rather than assumed from the payer name.

Why this decides so much: filing into the wrong process ends the dispute on eligibility rather than on the merits. Of the 1,449,900 disputes closed nationally in the second half of 2025, 271,399 — about 19% — were closed as ineligible, and the non-initiating party challenged eligibility in 574,128 of the 1,372,563 disputes initiated. What eligibility turns on.

Before you file against Anthem

  • Establish the plan type from the plan document or summary plan description before choosing a route — the card alone will not tell you, and 33% of Anthem disputes involve a category ERISA does not preempt.
  • Note that 3,731 Anthem disputes were recorded with no issuer response, so the plan type may not be established for you.
  • Confirm the 30-business-day open negotiation notice date, since the four-business-day filing window runs from the 31st business day after it.
The plan name on the card is not the plan type. A self-funded employer plan is very often administered by a carrier whose name appears on the card exactly as a fully insured plan would. The plan document settles it; the card does not.
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What the Federal Medians Say Your Claims Are Worth

Volume tells you who is in the room. What a decided dispute is worth depends on the service and the size of the claim, not on the payer: CMS reports the median prevailing offer at 5.22× the plan's own qualifying payment amount on claims under $100, falling to 1.69× at $10,000 and above, and it varies by specialty from 2.00× to 25.85×.

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