Frank Pallone, Jr., the ranking member of the Energy and Commerce Committee, has sent oversight letters to six independent dispute resolution entities questioning their compliance with the No Surprises Act.
The six organisations contacted are C2C Innovative Solutions, Commence, Dane Street, EdiPhy Advisors, National Medical Reviews, and ProPeer Resources.
The No Surprises Act was designed to shield patients from unexpected medical bills by requiring insurers and providers to negotiate for 30 days before escalating payment disputes to arbitration.
Under the arbitration process, a neutral IDR entity selects one of the parties’ payment offers, with the system intended to reduce financial burdens on ordinary patients caught between providers and insurers.
However, growing criticism has emerged that IDR entities are not operating as Congress intended, with arbitrators awarding payments that critics say are driving up costs for consumers.
IDR entities awarded approximately $15 billion in payments to providers in 2025, with providers winning more than 85% of determinations at amounts more than six times local in-network rates.
“For too long, patients were caught in the middle of billing disputes between providers and health plans,” Pallone said in the letters, adding that the process “is not functioning as Congress intended.”
Pallone warned that the current trajectory of the IDR process is “resulting in increased out-of-pocket costs and higher premiums for consumers,” a concern he stressed throughout the correspondence.
Each of the six companies has been asked to provide annual data on dispute volume, eligibility determinations, and default judgments since 2023, as well as details on training, credentials, and compensation for workers making IDR determinations.
The companies must also identify the ten organisations that have initiated the most disputes with them since 2023, with responses required by September 24.
Pallone’s letters also highlight the rising number of surprise medical bills reaching IDR rather than being resolved through negotiations, signalling a breakdown in the earlier stages of the dispute resolution process.
A study released in August by researchers at the Georgetown University Center on Health Insurance Reforms estimated that costs related to IDR reached $22.4 billion at the end of 2025.
The same study, based on federal data on the No Surprises Act, found that 2.6 million disputes were initiated in 2025, representing a 77% increase over 2024.
The sharp rise in arbitration cases and escalating payment awards have intensified scrutiny of whether the IDR system is delivering value for patients or simply shifting costs onto them.