Why readiness and defensibility
The cost of a wasted filing moved. It didn't disappear.
Rising volume, a 5 business day eligibility clock, a 50-item batching cap, non-refundable fees on dead filings, and post-TMA III QPA scrutiny make pre-filing readiness the operational priority. Here is the case, with every figure sourced and dated.
The pressure, quantified
What the operators are up against
We quantify pressure and readiness, not outcomes. We make no win-rate or dollar-recovery claims.
~2.56M
Verifiedfederal IDR disputes initiated in 2025
Volume has run orders of magnitude beyond the ~17,000/year originally expected.
CMS PUF, 2025
5 business days
Verifiedeligibility review window
A short clock that punishes an unclean open-negotiation record or a mis-batched filing.
CMS-9897-F, Aug 3, 2026
50 items
Verifiedbatching cap on qualified IDR items and services
Mis-assembled batches get split or dismissed after the non-refundable fee is spent.
CMS-9897-F, Aug 3, 2026
~42%
Verifiedof initiated disputes had eligibility challenged by payers
Defensibility is now as important as the submission itself.
CMS PUF, Q3–Q4 2025
The through-line
Discipline beats volume
The loud incumbents compete on win-rate and dollars recovered. We compete on the input discipline that makes those outcomes defensible and keeps teams out of the ineligibility-and-litigation trap now dominating headlines.
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.
See your group's IDR footprint
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