Air Ambulance: 2.37× the Insurer's Own Benchmark
In the last quarter of 2025 the median prevailing offer in air ambulance disputes was 2.37× the qualifying payment amount — the figure the plan itself calculated. Across the second half of 2025, certified IDR entities decided 20,416 payment determinations in this category, covering 26,598 items or services.
What the Federal Data Says About Air Ambulance
How to read this. The qualifying payment amount is the plan's own calculated benchmark — generally the median contracted rate for the service in the geographic area. A median prevailing offer of 2.37× QPA means that in half of the decided disputes in this category, the offer the certified IDR entity selected was at least 2.37 times what the plan had calculated. It is a measure of the gap between the plan's benchmark and what an independent entity found defensible. It is not a prediction, a guarantee, or an average recovery for any particular practice, and it does not include disputes that were found ineligible or that closed before a determination. CPT range for this category: Air ambulance transport, reported separately by CMS from all other item and service categories.
Source: CMS, Federal Independent Dispute Resolution Process — Supplemental Tables, Q3 and Q4 2025, Table 14 (prevailing offers relative to QPA by specialty) and Table 12 (payment determination outcomes). Published by CMS here.
Why Air Ambulance Claims End Up Out of Network
Air ambulance is the one transport category Congress brought inside the No Surprises Act, and the Departments report it separately from every other service in every published dataset. The patient is protected from balance billing for out-of-network air ambulance transport, and the dispute moves to the plan and the operator.
Two features distinguish air ambulance disputes. First, ground ambulance was deliberately left out of the federal process — a distinction that catches operators running both. Second, air ambulance claims are individually large, and the federal data shows that the largest claims close the smallest multiple relative to the plan's benchmark. The absolute dollars are still substantial; the percentage gap is not.
Deciding Whether a Claim Is Worth Disputing
Three things determine whether a specific claim belongs in federal arbitration, and none of them is the specialty itself.
1. Is the claim eligible?
Roughly one in five disputes initiated in 2025 was found ineligible — the single largest source of wasted effort in this process. Eligibility turns on whether the item or service falls under the federal protections rather than a state process, whether open negotiation ran its full 30 business days, and whether the dispute was filed within the four-business-day window that follows. Getting this wrong costs the fee and the claim.
2. Does the arithmetic work?
Since June 11, 2026, the administrative fee is $15 per party per dispute, down from $115. The certified IDR entity fee is set within a range published annually by the Departments and is paid by the non-prevailing party. Against those costs, the relevant question is the gap between the plan's payment and a defensible value for the service — and the federal data shows that gap by claim size is largest on smaller claims, not larger ones.
3. Can the claims be batched?
Qualifying claims may be submitted together in a single dispute. For a air ambulance practice generating similar claims against the same plan, batching is usually what turns a marginal economic case into a clear one.
We review claims against these three tests before anything is filed, and we are paid only out of what is actually recovered. If the claims do not clear the tests, we say so.