When the No Surprises Act took effect, federal regulators projected roughly 17,000 arbitration cases a year. Dispute volume has climbed into the hundreds of thousands annually, providers prevail in a large majority of cases that reach independent dispute resolution, and the June 2026 Federal IDR final rule has added new eligibility, batching, and communication requirements on top of an already strained process.

Most of the conversation happening right now is about how payers can compete harder inside that arbitration system: faster intake, sharper briefs, better win rates once a dispute is already in the IDR queue. That's a reasonable response to a real problem. But it treats IDR as the starting line, when for most payers it should be the last resort.

The Real Cost Center Is Upstream of Arbitration

Every dispute that reaches a certified IDR entity already represents a failure of the 30 days that came before it: the open negotiation window where a defensible, well-supported offer could have resolved the claim without administrative fees, entity fees, or a coin-flip outcome decided by someone outside your organization. By the time a case is in IDR, the payer has already lost leverage. The question stops being "what's the right price for this claim" and becomes "which number does the arbitrator pick."

That's the framing payers need to challenge. The goal isn't to get better at winning arbitration. The goal is to make arbitration unnecessary as often as possible, by walking into open negotiation with a price that both sides can actually stand behind.

What "Defensible" Actually Means

A defensible offer isn't a number pulled from a benchmark table or padded to leave room for negotiation. It's a reimbursement rate built on current, claim-specific market data: geography, specialty, site of service, and the qualifying payment amount calculation done correctly the first time. When that number is right, providers have less incentive to escalate, and when a case does move to IDR anyway, the payer's position holds up because the pricing methodology was sound from the first submission.

It's why we approach No Surprises Act work differently than most of what's being marketed to payers right now. Rather than building our approach around compliance alone, AMPS invested early in developing an integrated strategy that combines strategic pricing methodologies, experienced legal professionals, dedicated negotiators, and operational expertise. Each discipline strengthens the next, creating a connected model designed to protect plan dollars while maintaining the flexibility to evaluate every claim on its own merits. That accuracy is what makes an offer defensible in open negotiation and durable if a case escalates. Across the book of business we support, roughly 93% of disputes are resolved before they ever reach IDR. That's not a byproduct of a smarter arbitration playbook. It's the result of getting the price right early enough that arbitration isn't worth pursuing.

We've also seen payers using PriceDynamix reduce overall out-of-network plan spend by 30 to 35%, not by fighting harder over each individual claim, but by pricing consistently and defensibly across the entire book from the start.

What This Looks Like With Real Claims

A large payer brought in PriceDynamix to reprice their out-of-network claims and in roughly three months with 207,000 claims, AMPS generated $26 million in savings for that plan. Of the 758 disputes that came out of that claim volume, 757 were resolved without ever going to IDR, a 99.9% pre-IDR resolution rate.

That's the model working at scale: a defensible price on the vast majority of claims from the start, so the arbitration system becomes the exception rather than the operating norm.

Why This Distinction Matters More After the June 2026 Rule

The new Federal IDR requirements tighten eligibility screening, change batching rules, and add reporting obligations. Vendors across the market are responding with AI-driven tools to help payers move faster through intake and build stronger cases once a dispute is filed. That's useful, and payers should expect their technology partners to keep pace with regulatory change.

But faster processing inside IDR doesn't change the underlying economics. Providers still win most cases that reach arbitration, and every case that gets there still costs a payer in fees, staff time, and unpredictability, regardless of who ultimately prevails. A payer who resolves 93% of disputes before IDR is spending less, not just winning more efficiently on the remaining 7%.

What This Looks Like in Practice

For a payer or TPA evaluating how to handle rising OON dispute volume under the new rule, the questions worth asking a vendor aren't only "how do you help us win IDR cases." They're:

• How is the initial offer priced, and how current is the underlying data?
• What percentage of disputes are resolved in open negotiation before IDR is ever filed?
• Is that pricing methodology consistent enough to hold up if a provider does escalate?
• Does the technology reduce dispute volume over time, or just process existing volume faster?

Those questions point payers toward the metric that actually protects plan spend and administrative capacity: disputes avoided, not disputes won.

Read the full interview on FierceHealthcare.

The Path Forward

The No Surprises Act isn't going to generate fewer disputes on its own, and the regulatory environment will keep shifting as CMS refines the process. What payers can control is the quality of the offer they make on day one. Getting that right, consistently, at scale, is what turns IDR from a recurring cost center into an occasional exception.

The four questions above are a reasonable place to start with any pricing partner, including AMPS. If you'd like to walk through how AMPS answers them for your book of business, reach out here: www.amps.com/strategy

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