Why Can't We Be Friends? Thoughts on IDR Process Headwind to Commercial LOB

Research evidence excerpt

Why Can't We Be Friends? Thoughts on IDR Process Headwind to Commercial LOB

Global Research INDUSTRY UPDATE

July 21, 2026

■Managed Care Why Can't We Be Friends? Thoughts on IDR

Process Headwind to Commercial LOB

TD SECURITIES (USA) LLC - WASHINGTON THE TD COWEN INSIGHT

RESEARCH GROUP - USA

On 7/16, UNH called out incremental cost pressure related to commercial independent disputeMACRO POLICY

resolution (IDR) and associated 2026 trend acceleration. Examining public data through 2Q25,

Molly T. Turco UNH disputes per 1k members are much higher vs peers. Plans have aggressively lobbied

202 868 5309

IDR for months, but a policy fix is unlikely this year. We see potential ASO exposure to IDR via

molly.turco@tdsecurities.com

Shared Savings arrangements.

TD SECURITIES (USA) LLC

EQUITY RESEARCH Our View (Turco)

■The No Surprises Act (NSA) created new protections against out-of-network balance billingRyan Langston

646 562 1418 in commercial and established a new process of independent dispute resolution (IDR). Plans

ryan.langston@tdsecurities.com argue it's too pro-provider and PE-backed entities have exacerbated the problem, resulting

in more arbitration going in favor of providers than expected, as described here.

Charles Rhyee

646 562 1376 ■An IDR fix has been a top lobbying priority for impacted plans throughout the summer, both

charles.rhyee@tdsecurities.com to the Hill and CMS. See examples of lobby materials here and here.

Christian Borgmeyer, CFA ■CMS states NSA is too prescriptive to allow them to address concerns. There is bipartisan

646 562 1430

traction for a leg fix (e.g. civil monetary penalty for submitting ineligible claims, IDR

christian.borgmeyer@tdsecurities.com

oversight for consistency, prompt pay for providers from plans). However, no fix is likely in