ClearHealth Strategies in Federal IDR Disputes
ClearHealth Strategies appears as the non-initiating party in 53,289 disputes. Self-funded plans account for 83% 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 | 44,425 | 83% | Federal — ERISA preempts state regulation |
| Fully insured group plan | 331 | 1% | A state process may apply |
| Individual market | 202 | 0% | Depends on the state |
| Federal Employees Health Benefits carrier | 48 | 0% | Federal |
| No issuer response | 8,275 | — | Plan type not established |
Source: CMS, Federal IDR Supplemental Tables, Q3 and Q4 2024, 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 83% 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. Another 8,275 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. About 19% of disputes initiated nationally in 2024 were found ineligible, and eligibility was challenged by the other side in 41% to 43% of disputes in the second half of that year. What eligibility turns on.
Before you file against ClearHealth Strategies
- Expect the federal route for most claims, given the 83% 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 8,275 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 5.53× the plan's own qualifying payment amount on claims under $100, falling to 1.73× at $10,000 and above, and it varies by specialty from 2.26× to 16.75×.
The medians for your specialty · The full federal dataset · What this costs