No Surprises Act and IDR in 2026: What Providers Win, What Changed, and How to Recover More

The No Surprises Act has created a significant revenue recovery opportunity for out-of-network providers. Providers, facilities, and air ambulance providers prevailed in approximately 88% of determinations in the first half of the year and 85% in the second half.

The numbers point to something every CFO should be asking: How much underpaid out-of-network revenue is still sitting inside claims your organization has already processed?

For many providers, the challenge is no longer understanding that IDR exists. It is identifying where meaningful recovery opportunities exist and having the technology, payer intelligence, and expertise to pursue them at scale.

How the No Surprises Act got here: 2022 to 2026

Where Out-of-Network Revenue Gets Left Behind

Underpayments are one of the least visible sources of revenue loss in healthcare. Industry benchmarks put commercial payer underpayments at roughly 1% to 3% of net patient revenue annually, with some organizations losing considerably more. Unlike denials, underpayments do not trigger a workflow. The claim is paid, the account closes, and the shortfall disappears into the baseline.

Out-of-network claims are especially exposed to this pattern. An out-of-network claim can be paid and closed while additional reimbursement is still recoverable through the No Surprises Act. That is where revenue gets missed. The payment gets posted, the claim disappears from view, and the underpayment becomes part of the financial baseline.

Across a high volume of out-of-network claims, that gap can become significant. The question for CFOs is simple: How much revenue has been posted as paid when it was actually underpaid?

What IDR Recovery Looks Like in Practice

A four-practice anesthesia group had received just $47,330 in initial payments across 44 out-of-network claims from major national payers. Plutus Health pursued those claims through the No Surprises Act process. The result:

• $47,330 in initial payer payments
• $298,573 in accepted offers
• $251,243 in additional reimbursement recovered

These claims had already been processed and paid. The opportunity came from identifying where reimbursement fell short and knowing which claims were worth pursuing.

Why IDR Volume Does Not Equal IDR Opportunity

More disputes do not automatically mean more recovery. For revenue leaders, the bigger question is how much recoverable revenue is sitting inside claims that have already been processed, paid, or written down.

Federal IDR sits across a changing mix of jurisdiction rules, plan types, payer behavior, filing requirements, and regulatory deadlines. That makes volume a poor measure of success. The real opportunity is identifying where meaningful reimbursement can still be recovered and pursuing it with discipline, fewer low-value pursuits, stronger recovery opportunities, and a clearer view of revenue that may otherwise be left behind.

“The biggest mistake providers make with IDR is treating every underpayment the same way. Recovery comes from disciplined case selection and deep payer expertise, not from filing everything and hoping something sticks.”

What the numbers do not tell you

The win rates above are real, but they come with context every CFO should understand before treating IDR as guaranteed revenue.

• The rate reflects outcomes across the disputes providers chose to pursue, not every underpayment in the market. It is an average, not a guarantee for any individual claim.
• The math behind those numbers is also still being litigated. The QPA calculation methodology has been challenged in court and remains unsettled following the Texas Medical Association rulings; the benchmark at the center of every dispute is itself under legal scrutiny.
• And filing carries real cost. Insurers challenge a meaningful share of disputes as ineligible, and a rejected filing costs both time and the administrative fee.

None of this argues against pursuing IDR. It argues for treating it as a disciplined, expertise-led function, not a blanket policy.

How OlympusAI and PIE Strengthen IDR Recovery

At IDR scale, the challenge is not simply finding underpayments. It is turning large volumes of claims and payer data into meaningful recovery opportunities.

Plutus Health combines OlympusAI, our Payer Intelligence Engine (PIE), and experienced IDR specialists to bring greater intelligence and consistency to that work. OlympusAI applies automation and intelligence across the revenue cycle, while PIE provides deeper visibility into payer behavior and reimbursement patterns. Our IDR specialists add the regulatory and operational expertise needed to act on those insights.

The technology does not replace IDR expertise. It gives our specialists better intelligence to work with at scale.

What Is Changing in 2026

The 2026 Federal IDR final rules introduce some of the biggest operational changes since the process launched.

• Lower filing cost: The administrative fee dropped from $115 to $15 per party for disputes initiated on or after June 11, 2026.
• New batching rules: Beginning November 1, 2026, updated batching provisions apply to disputes with open negotiation periods starting on or after that date, including a limit of 50 line items per batched dispute.
• IDR Gateway: CMS is preparing to transition the Federal IDR process to a centralized IDR Gateway in late 2026, giving organizations one place to initiate, manage, and track disputes.
• New remittance requirements: Beginning with items and services furnished on or after January 1, 2027, payers will be required to use specified CARCs and RARCs to communicate information relevant to the Federal IDR process.

For revenue leaders, these changes make 2026 an important preparation year. Lower administrative costs may expand the financial opportunity, while new batching, remittance, and technology requirements will change how organizations interact with the Federal IDR process.

How much IDR revenue are you leaving behind?

With millions recovered in NSA and IDR disputes and a track record against major national payers, Plutus Health helps out-of-network-heavy specialties such as ER and ASC recover more of what they're owed.

Start with a sample of your claims. Our free IDR Opportunity Assessment shows you where additional recovery potential may exist, before you decide what comes next.