Field Note · June 11, 2026 · Economics

Arbitration was built for 17,000 disputes. It got 1.2 million.

Field Note Figure · 17,000 vs 1.2 millionpause
Watch the filings bar bury the projection. The thin indigo sliver is the entire 17,000-dispute annual forecast. Georgetown CHIR, 2026.
1.2M
disputes filed in the first six months of 2025. The arbitration system was built to handle about 17,000 in a year. Georgetown CHIR; CRS R48738.

When Congress passed the No Surprises Act, the government estimated its arbitration system would handle about 17,000 payment disputes a year. In the first six months of 2025, providers and insurers filed roughly 1.2 million. That is more than double the same stretch of 2024, and on an annual pace it runs near 140 times what the rule writers planned for. The figures come from Georgetown's Center on Health Insurance Reforms, reading the government's own dispute data, alongside the Congressional Research Service.

Picture a clinic built for seventeen thousand visitors a year that finds millions lined up at the door before lunch. The administrative fees tell the same story: the arbitration process collected about 844 million dollars in fees in that single half year, almost as much as it had collected in the three years before it combined.

A system priced like a rare exception became a routine billing channel, and the side that files keeps winning: providers prevailed in roughly 85 percent of 2024 determinations, so every default is an invitation to file again.

Source: Georgetown Center on Health Insurance Reforms, March 2026; CRS R48738, 2024 determinations · The 140x annual-pace figure annualizes six-month filing data, an estimate · Figures point-in-time
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