Anesthesiology: 3.61× the Insurer's Own Benchmark
In the last quarter of 2025 the median prevailing offer in anesthesiology disputes was 3.61× the qualifying payment amount — the figure the plan itself calculated. Across the second half of 2025, certified IDR entities decided 116,912 payment determinations in this category, covering 164,331 items or services.
What the Federal Data Says About Anesthesiology
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 3.61× QPA means that in half of the decided disputes in this category, the offer the certified IDR entity selected was at least 3.61 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: 00100–01999 (anesthesia services), with 99100–99140 for qualifying circumstances.
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 Anesthesiology Claims End Up Out of Network
Anesthesiology is an ancillary service under the No Surprises Act for exactly the same reason as radiology: the patient selects a surgeon and a facility, not the anesthesiologist. Balance billing is prohibited and the notice-and-consent exception is unavailable, so the plan's payment is the only payment — unless the group disputes it.
Anesthesia carries an additional complication no other specialty shares. Anesthesia is billed in units — base units for the procedure plus time units — multiplied by a conversion factor. A plan's qualifying payment amount for anesthesia therefore rests on a conversion factor rather than a per-service rate, and how that factor was derived is frequently the substance of the dispute.
That is a technical argument, and technical arguments are won with documentation: the anesthesia record, the units billed, the conversion factor applied, and comparable rates in the same geographic area.
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 anesthesiology 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.