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.
What CMS Reports
| Plan type | Disputes | Share | Which process it points to |
|---|---|---|---|
| Self-funded or partly self-funded employer plan | 62,945 | 56% | Federal — ERISA preempts state regulation |
| Fully insured group plan | 5,462 | 5% | A state process may apply |
| Individual market | 180 | 0% | Depends on the state |
| Federal Employees Health Benefits carrier | 3,438 | 3% | Federal |
| Non-federal government plan (state or local) | 37,045 | 33% | Depends on the state — not an ERISA plan |
| Church plan | 3 | 0% | Depends on the state — not an ERISA plan |
| No issuer response | 3,731 | 3% | Plan type not established |
| All plan types | 112,804 | 100% |
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.
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.
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×.
The medians for your specialty · The full federal dataset · What this costs