No Surprises Act Arbitration in North Dakota
Physicians and facilities in North Dakota initiated 102 federal IDR disputes in the second half of 2025 — the 50th-highest volume in the country, and 0.0% of the national total. We work these claims for North Dakota practices from our office in California; the process is federal and runs identically in every state.
What the Numbers Show
| Period | Disputes initiated in North Dakota |
|---|---|
| Q3 2025 (July–September) | 50 |
| Q4 2025 (October–December) | 52 |
| Second half of 2025 | 102 |
| Of which air ambulance transport | 85 |
Source: CMS, Federal IDR Supplemental Tables, Q3 and Q4 2025, Table 7 (dispute initiations by state or territory). CMS notes that batched disputes covering items or services in several states are counted in each of those states, so state figures sum to more than the national total. National win-rate figure from Table 12 for the same period: 977,661 of 1,145,039 payment determinations. Published by CMS here.
Which Process Applies to a North Dakota Claim
CMS does not flag North Dakota as having a specified state law or All‑Payer Model Agreement covering these disputes. In practical terms that simplifies the analysis considerably: for out-of-network claims falling under the No Surprises Act protections, the federal IDR process is the route, without the state-versus-federal question that complicates filing in neighbouring states.
That does not make eligibility automatic. About one in five disputes initiated nationally in 2025 was still found ineligible — most often on timing, on whether the item or service is covered by the protections at all, or on batching that did not meet the requirements.
What we check before anything is filed
- Whether the patient's plan is self-funded, fully insured, a government plan or a FEHB carrier — this decides state versus federal more often than anything else.
- Whether the item or service falls under the federal protections: emergency care, or ancillary services at an in-network facility, or non-emergency care where notice and consent was not validly obtained.
- Whether the 30-business-day open negotiation period was properly opened and completed, and whether the four-business-day window to initiate has passed.
- Whether claims can be batched, which is usually what decides the economics.
We are paid out of what is recovered. If the claims do not survive these checks, filing them costs you money and we say so before anything is submitted.
Start With Your Own Numbers
The federal data says what happened across hundreds of thousands of disputes. It says nothing about your claims — and it is your denials, your QPAs and your dates that decide whether there is anything worth pursuing.
Send us a sample of EOBs. We tell you which claims are eligible, what the timing looks like, and whether the arithmetic works at $15 per party per dispute. That review costs nothing and carries no obligation.