CMS Publishes Federal IDR Public Use Files: Latest Release

What Did CMS Release?

The CMS page on Independent dispute resolution reports lists the Federal IDR PUF for 2025 Q3 and 2025 Q4, both dated "as of July 22, 2026," together with matching supplemental tables and a supplemental background document for July 1 to December 31, 2025. CMS says it updated the PUF documentation on July 22, 2026.

The page also notes a structural change: "Beginning with the Federal IDR PUF that covers payment determination data through 2025 Q3 and Q4," each dispute line item now includes the name of the certified IDR entity that conducted the payment determination.

What Is in the Public Use Files?

The General Information document says the files hold line-item data on payment determinations that certified IDR entities closed during the quarter. Data come from web forms that disputing parties submit and from outcomes that entities report in the Federal IDR portal. It describes three groups of data:

• OON Emergency and Non-Emergency: outcomes of payment determinations for out-of-network emergency and nonemergency items and services.
• OON Air Ambulance: outcomes for out-of-network air ambulance services.
• QPA and Offers: offer amounts and qualifying payment amounts for each payment determination closed in the quarter.

CMS releases both Excel and CSV files for each tab beginning with the first quarter of 2025. CMS also publishes a data dictionary that users should review before analysis.

What Does the Data Leave Out?

Line items determined ineligible, needing resubmission, withdrawn by the parties or excluded for other administrative reasons are not in the files. The data reflect disputes closed in the quarter, so a dispute still open does not appear.

CMS also protects privacy. It redacts potential PHI or PII from free text and suppresses QPA and offer data where line items with the same service code were submitted fewer than 10 times in the same geographic region. In the files, N/R means a value was not reported, often because a party did not submit an offer, and N/A means not applicable.

How Can a Billing Team Use the Files?

1. Download the quarter that matches the service dates you dispute, and the data dictionary with it.
2. Filter to your service code and compare the offers and QPAs shown for closed disputes with the offer you plan to submit.
3. Check the certified IDR entity column on 2025 Q3 and Q4 lines, then see how decisions on similar line items vary by entity.
4. Remember the suppression rule: a blank for a rarely disputed code in your region is expected, not an error.
5. Treat the files as background, not a prediction of your own result.

The federal IDR process page covers filing steps, and the QPA page explains how the QPA is built. Emergency groups can read the guide to the No Surprises Act for ER groups.

What Is Still Open?

The General Information document says the Departments will release additional files when the data are available, and the statute requires publication of information about the IDR process for each calendar quarter. CMS's page lists no date for the 2026 data.