Providers Prevail in Surprise Billing Disputes; HaloMD Emerges as Leading Middleman
by Jinghong Chen
HaloMD, a third-party independent dispute resolution (IDR) services provider, has emerged as the top “middleman” under the No Surprises Act. Its share of initiating disputes jumped from just 1% in 2023 to 22% by the second quarter of 2025, according to Payer Perspective’s analysis of newly released CMS data.
The No Surprises Act, passed in 2021, banned the practice of billing patients for the difference between what their insurer pays and what a provider charges when patients unknowingly receive care from an out-of-network (OON) provider. The law also established a federal IDR process that OON providers and insurers can use to determine the OON rate that providers should receive if the two parties fail in their own attempts to negotiate.
In the first half of 2025, a total of 1,186,812 surprise billing disputes were initiated through the federal IDR process, 39% more than the last six months of 2024. Over 81% of those cases were filed by providers, according to an analysis of CMS data. Among resolved disputes involving emergency and non-emergency services (excluding air ambulance services), providers won the majority, with their win rate rising from 68% in the first quarter of 2023 to 88% in the second quarter of 2025.
Under the IDR process, providers submit unresolved bills to an HHS-approved arbitrator, who then selects an amount submitted by either the payer or the provider using criteria laid out by HHS. The arbitrators are obliged to consider the qualifying payment amount (QPA) — based largely on median regional in-network rates for a service in a given area — in their decisions.
Neurology and surgery providers using the IDR system won at especially higher prevailing rates. In the first half of 2025, the median payment determination among disputes involving neurology and neuromuscular procedures was more than 23 times the QPA. For surgical services, the median prevailing offer reached nearly 1,320% of the QPA.
A relatively small number of providers and their representatives initiated most surprise billing disputes, CMS data show. The top initiating parties over the past two years — Team Health, HaloMD and SCP Health — represent thousands of clinicians across multiple states. Team Health, SCP Health and the fourth-largest initiating party, Radiology Partners, are all backed by private-equity firms.
HaloMD ranked second overall in volume and has become the top initiating party since the fourth quarter of 2024. The third-party IDR services provider, with a win rate of more than 88% in the first half of 2025, is now facing at least four lawsuits alleging abuse of the IDR system and violations of the federal Racketeer Influenced and Corrupt Organizations (RICO) Act. In May, Elevance, Inc.’s Georgia subsidiary sued the company and three Georgia providers, accusing them of falsely attesting to claim eligibility, overwhelming the IDR process and inflating payment offers. A month later, Elevance’s Ohio subsidiary, Community Insurance Company, made similar allegations against HaloMD and five providers in Ohio. In August, Blue Cross Blue Shield of Texas alleged that HaloMD and related parties submitted fraudulent claims to IDR entities.
In the first half of 2025 alone, nearly 29% of resolved disputes initiated by HaloMD involved Blue Cross Blue Shield of Texas, according to Payer Perspectives’ analysis.
About 17% of disputes submitted in the first six months of 2025 were actually ineligible for IDR, CMS says. Although the share of ineligible cases has declined from 69% in the first six months of 2022, they continued to clutter up the system. A study published in Health Affairs estimated that the IDR process has generated at least $5 billion in total costs from 2022 to 2024, with over 17% attributed to administrative costs and 38% to providers’ and payers’ internal costs.
Meanwhile, the industry continues to await a final rule from regulators that would clarify key aspects of IDR operations. Payer groups argue that some providers are using the IDR process strategically to drive higher reimbursements, while providers cite strong win rates and high reimbursement amounts as evidence that insurers are filing artificially low payment offers.