Neutral policy analysis · not marketing
The IDR policy hub
Neutral, policy-grade explainers of federal IDR, written to be useful to operators, employers, and regulators alike. We keep verifiable data, interested-party advocacy, and contested analysis visibly distinct, and we date everything.
Explainers
Read the analysis
7 min · as of 2026-08-03
CMS-9897-F mechanics: a neutral explainer of the June 2026 Final Rule
A plain-English walkthrough of the 2026 IDR Operations Final Rule, fees, batching, eligibility review, registration, the Gateway, and the cooling-off change.
Read →7 min · as of 2026-03-31
Reading the CMS IDR Public Use Files: what the 2025 data shows
A neutral summary of federal IDR volumes, provider/payer prevailing shares, ineligibility rates, and specialty variation from the CMS PUFs.
Read →6 min · as of 2026-08-11
The QPA after TMA III: what the Fifth Circuit's ruling means
A neutral reading of the August 2026 en banc TMA III decision on QPA methodology and its operational implications. Not legal advice.
Read →6 min · as of 2026-08-11
Estimating the cost of IDR: a balanced look at the Georgetown analysis
A balanced summary of the Georgetown/Health Affairs cost estimate, its QPA-benchmark caveat after TMA III, and the provider rebuttal.
Read →5 min · as of 2026-08-11
When payers do not pay IDR awards: what providers are seeing
A neutral summary of the enforcement-and-non-payment trend and the private-right-of-action question. Context, not counsel.
Read →How we label evidence
- VerifiedCMS Public Use File volumes, ineligibility rates, fee schedules, published rule text, and the TMA III holding.
- AdvocacyFigures from parties with a stake, AHIP/BCBSA surveys and ERIC one-pagers (payer side); AMA/ACEP/ACR campaigns and vendor press releases (provider side). Cited as claims, not facts.
- ContestedRigorous analysis that rests on a disputed input, e.g., the Georgetown/Health Affairs estimate, which relies on a QPA benchmark the Fifth Circuit held was calculated unlawfully.
We deliberately avoid repeating headline figures that rest on contested inputs. Where an estimate depends on a disputed benchmark, we say so and link the source rather than restating the number as fact.