ClearHealth Strategies in Federal IDR Disputes
ClearHealth Strategies appears as the non-initiating party in 95,628 disputes. Self-funded plans account for 85% of its profile — one of the highest shares in Table 9.
What CMS Reports
| Plan type | Disputes | Share | Which process it points to |
|---|---|---|---|
| Self-funded or partly self-funded employer plan | 81,497 | 85% | Federal — ERISA preempts state regulation |
| Fully insured group plan | 1,087 | 1% | A state process may apply |
| Individual market | 8,914 | 9% | Depends on the state |
| Federal Employees Health Benefits carrier | 2,911 | 3% | Federal |
| Non-federal government plan (state or local) | 4 | 0% | Depends on the state — not an ERISA plan |
| No issuer response | 1,215 | 1% | Plan type not established |
| All plan types | 95,628 | 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. Note that ClearHealth Strategies is a cost-containment vendor that appears in disputes as the plan's representative, not as the insurer. CMS publishes these tables here.
Federal Process or State Process
At 85% self-funded, the overwhelming majority of disputes involving ClearHealth Strategies proceed through the federal IDR process, since ERISA bars state regulation of self-funded employer plans. Fully insured plans account for just 1%, so a state-route alternative applies to almost none of this volume. The individual market accounts for 9% and FEHB carriers 3%. Another 1,215 disputes show no plan response, meaning the plan type was never established.
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 ClearHealth Strategies
- Expect the federal route for most claims, given the 85% self-funded share, and prepare federal IDR documentation accordingly.
- Confirm whether the entity on the EOB is the plan administrator or a third-party processor, and identify the actual plan.
- Obtain plan-type confirmation early to avoid the undetermined status reflected in 1,215 disputes.
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