IDR for critical care: the critical care claim record
What critical care lines won in 2025, why emergency department and ICU care both qualify, and how the time codes pay.
Critical care is one of the fastest growing corners of federal IDR: volume almost doubled in a year, from 26,576 disputes in 2024 to 52,569 in 2025, and providers won 88.07 percent at a median of 3.73 times the QPA. The median decision now takes 31 days, down from 81. Most disputes come from the emergency department and the rest from inpatient units. This site explains who qualifies, what the first-block and add-on time codes pay, and where the money sits, as the published decisions show it.
All 3.39 million federal IDR disputes published by CMS, 2023 through 2025. Explore the data at idrexplorer.com.
Federal IDR is the No Surprises Act arbitration process for out-of-network claims. Critical care claims reached it 52,569 times in 2025, and providers won 88.07 percent at a median of 3.73 times the QPA. Critical care billed in an emergency department is an emergency service, and intensivist work at a participating hospital is on the list of services patients can never be asked to waive.
Volume nearly doubled and decisions got faster
The critical care files grew from 5,672 disputes in 2023 to 26,576 in 2024 and 52,569 in 2025, a 98 percent rise in the latest year. Quarterly volume peaked at 14,790 in the second quarter of 2025 and eased to 13,077 in the fourth. Provider wins rose from 78.56 percent in 2023 to 83.82 in 2024 and 88.07 in 2025, and the median time to a decision fell from 81 days in 2024 to 31. Default decisions, where one side never submitted an offer, held near 18 percent of disputes. Critical care accounts for 2.41 percent of all 2,180,938 disputes published for 2025.
Mostly the emergency department, plus an inpatient stream
Two codes define the group: 99291 for the first block of critical care time and 99292 for each added 30 minutes. Of the 52,132 disputes with a 99291 line, 48,731 (93.48 percent) came from the emergency department and 3,119 (5.98 percent) from inpatient units. Counting lines that report a QPA and offers, a 99291 line had a median QPA of $315.23 and a median decided award of $1,077.10, and provider wins on the code add up to $131.8 million in prevailing offers for 2025, against $44.2 million in 2024. The add-on code appears in 1,838 disputes and decided at a median of $2,400 against a $232.95 QPA.
Five filers, one large payer, and wide gaps in defaults
Five filer domains brought 70.47 percent of the 2025 disputes, 37,043 of 52,569, and 112 others shared the remaining 15,526. The largest alone filed 31.2 percent and won 93.4 percent. UnitedHealthcare was the plan in 16,723 disputes (31.8 percent), followed by Aetna with 6,246, Blue Cross Blue Shield of Texas with 5,913, and Anthem with 5,596. Default decisions ran 9.6 percent against UnitedHealthcare, 39.9 percent against Blue Cross Blue Shield of Texas, and 79.1 percent against Blue Cross Blue Shield of Florida.
States, plan types, and filing costs
Texas leads with 16,270 disputes, where providers won 85.4 percent and decisions came in at a median of 5.0 times the QPA. Florida follows with 5,885 and a 92.5 percent win rate, then Georgia with 3,697; the three states together produced 49.2 percent of the total. Self-insured employer plans were the plan type in 71.0 percent of disputes. Every dispute costs each party a $15 administrative fee, plus an IDR entity deposit that goes back to the winner. Lido IDR files for a flat fee per arbitration and sets each offer from the decided critical care results at idrexplorer.com.
Common questions
Can critical care physicians use federal IDR?
Yes. Critical care delivered in an emergency department is an emergency service under the No Surprises Act, and intensivist services at a participating hospital are on the list of services patients cannot be asked to waive. Out-of-network claims on commercial plans qualify. Medicare, Medicaid, and TRICARE claims do not.
What do critical care claims pay in federal IDR?
Providers won 88.07 percent of the 52,569 critical care disputes in the 2025 files, at a median of 3.73 times the QPA. Lines for 99291 had a median QPA of $315.23 and a median decided award of $1,077.10.
Does ICU critical care qualify as well as ED critical care?
Often. At a participating hospital, intensivist services are on the never-waivable list. After emergency care at any hospital, post-stabilization services stay protected unless the patient meets the strict conditions for consent. A planned stay at an out-of-network hospital is outside the Act. Inpatient units produced 3,119 of the 2025 disputes with a 99291 line.
How long does a critical care dispute take to decide?
The median critical care dispute in the 2025 files reached a decision in 31 days, against 81 days in 2024 and 79 in 2023. Default decisions, where one side never submitted an offer, accounted for 17.91 percent of disputes.
What does filing cost a critical care group?
The administrative fee is $15 for each party per dispute, and the certified IDR entity holds a deposit that returns to the winner. Percentage vendors keep 15 to 25 percent of what is recovered. Lido IDR files for a flat fee per arbitration, which suits a code that repeats across thousands of encounters.
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