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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.

The Published Count

What CMS Reports

95,628
Disputes with ClearHealth Strategies as non-initiating party, H2 2025
#6
Rank among the ten most disputed parties
85%
Of those disputes involved self-funded plans
1,215
Disputes where the plan type was never established
Disputes involving ClearHealth Strategies by plan type, the second half of 2025
Plan typeDisputesShareWhich process it points to
Self-funded or partly self-funded employer plan81,49785%Federal — ERISA preempts state regulation
Fully insured group plan1,0871%A state process may apply
Individual market8,9149%Depends on the state
Federal Employees Health Benefits carrier2,9113%Federal
Non-federal government plan (state or local)40%Depends on the state — not an ERISA plan
No issuer response1,2151%Plan type not established
All plan types95,628100%

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.

What It Means for Your Claim

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.
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×.

The medians for your specialty · The full federal dataset · What this costs

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