No Surprises Act Arbitration in Tennessee
Physicians and facilities in Tennessee initiated 46,792 federal IDR disputes in the second half of 2025 — the 8th-highest volume in the country, and 3.4% of all disputes initiated across the states and territories. We work these claims for Tennessee practices from our office in California. The process is federal and runs the same way everywhere, and CMS does not flag Tennessee as having a specified state law of its own.
What the Numbers Show
| Period | Disputes initiated in Tennessee |
|---|---|
| Q3 2025 (July–September) | 23,014 |
| Q4 2025 (October–December) | 23,778 |
| Second half of 2025 | 46,792 |
| Of which air ambulance transport | 2,029 |
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 Tennessee Claim
CMS does not flag Tennessee 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. 15.0% of disputes closed nationally in January–September 2026 — about one in seven — were 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.
Common Questions About Filing From Tennessee
Does Tennessee run its own arbitration process, or does my claim go federal?
CMS does not flag Tennessee as having a specified state law or All-Payer Model Agreement covering these disputes. For out-of-network claims that fall 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.
How many federal IDR disputes came from Tennessee?
46,792 federal IDR disputes were initiated in Tennessee in the second half of 2025 — 3.4% of all disputes initiated across the states and territories, and the 8th highest volume of any state or territory. The quarterly split was 23,014 in the third quarter and 23,778 in the fourth. These are counts of disputes filed, not of underpayments: a low number says how often practices here use the process, not how often they are underpaid.
Is federal IDR volume in Tennessee rising or falling?
Volume rose 3% between the quarters of the second half of 2025 — from 23,014 disputes initiated in the third quarter to 23,778 in the fourth. Across all states and territories the change over the same two quarters was +10.1%, so Tennessee moved slower than the national pace. A rising count means the process is being used more here, not that payers are underpaying more: CMS publishes filings, not underpayments, and the two are not the same measurement.
Are air ambulance claims counted separately for Tennessee?
Yes. Of the 46,792 disputes initiated in Tennessee, 2,029 involved out-of-network air ambulance services, which CMS reports as its own category because the No Surprises Act treats air ambulance transport under separate provisions. Ground ambulance sits outside the federal process entirely.
What decides whether a Tennessee claim is eligible at all?
Eligibility, not the merits, is where most filings are lost: 15.0% of disputes closed nationally in January–September 2026 — about one in seven — were found ineligible and never reached a decision (18.7% in the second half of 2025). The causes are the same everywhere — the wrong forum, a missed window, or a service the protections do not cover. The federal timetable is a 30-business-day open negotiation period, then a four-business-day window to initiate that begins on the 31st business day after that period started.