Flagship Capability

Independent Dispute Resolution (IDR) & No Surprises Act Advisory

Helping providers and health plans navigate one of healthcare's most complex reimbursement environments — through regulatory expertise, operational excellence, and winning dispute-resolution strategy.

Federal + State
Coverage across federal IDR & state frameworks
0
Out-of-network specialties supported
0
States & territories in scope
Enterprise
Program design & operating-model expertise
More Than Arbitration Support

We build NSA programs — not just IDR cases.

Most firms simply file disputes. Fulcrum is a strategic advisor that understands the entire ecosystem — from provider operations and contract strategy to the payer decision-making process and the federal and state regulatory frameworks that govern dispute resolution. Health systems, physician groups, private equity firms, revenue cycle organizations, and health plans rely on us to build scalable, profitable, compliant NSA programs.

Strategic advisoryRegulatory expertiseOperational designFinancial optimizationWinning IDR strategyReimbursement optimizationOrganizational transformation
Industry Authority

Built by the professionals who helped shape the industry

Fulcrum's team includes senior leaders who were among the earliest to build large-scale No Surprises Act compliance and Independent Dispute Resolution programs at national provider organizations — including experience drawn from enterprises such as Envision Healthcare and AmSurg.

Rather than merely reacting to the legislation, our team helped operationalize the processes, governance, analytics, workflows, and financial strategies required to manage the NSA at enterprise scale. We understand both the regulatory intent and the financial realities providers face.

We didn't just study the NSA. We helped operationalize it at national scale.
Envision HealthcareAmSurgNational physician enterprises
Federal IDR implementation
Multi-state dispute resolution
Provider operational design
Revenue cycle integration
Clinical documentation optimization
Arbitration strategy
Regulatory interpretation
Executive leadership
Team experience references prior roles at named organizations and does not imply endorsement by or affiliation with those organizations.
Federal vs. State Expertise

Every dispute begins with the pathway

Every dispute begins with determining whether a claim falls under federal or applicable state law. Fulcrum builds governance frameworks that route each dispute down the correct pathway from the outset — minimizing delays and improving recoveries. Select a framework to compare how it works.

Educational summary of framework structures. State rules vary; Fulcrum confirms the governing framework and current requirements for each claim.

Federal IDR Applicability by State — per CMS

Where CMS indicates the Federal IDR process applies, versus a "Bifurcated Process" in which a specified state law or All-Payer Model Agreement may govern the out-of-network rate. Hover a state; click a legend item to isolate it.

Interactive map requires a network connection to load state geography. The Federal IDR and Bifurcated-Process states are listed in the legend below and follow the CMS chart.
Federal IDR ProcessThe federal IDR process applies (28 states + D.C., plus the U.S. territories).
Bifurcated ProcessA specified state law or APMA may apply — review needed (e.g., CA, CO, FL, IL, MD, NY, OH, TX).
Bifurcated + self-insured opt-inBifurcated states that let self-insured plans opt into the state process: GA, ME, NV, NJ, VA, WA.
Alaska — special caseNot placed in either column of the chart; Alaska asserts its OON rules reach all claims, including air ambulance.

Source: CMS, "Chart for Determining the Applicability of the Federal Independent Dispute Resolution (IDR) Process." SSL/APMA information current as of January 11, 2023. Self-insured (ERISA) plans and air-ambulance claims are generally governed by the federal process nationwide, except where a self-insured plan has opted into a permitted state process. The federal IDR process does not apply to Medicare, Medicaid, CHIP, or TRICARE.

End-to-End NSA Advisory

From discovery to executive reporting

A complete operating model for out-of-network reimbursement under the No Surprises Act. Select a phase to expand it.

Building Winning IDR Strategies

Outcomes are decided long before arbitration

Successful determinations begin with case selection, evidence, and economics — not the submission deadline. Fulcrum builds strategies, not just filings.

01

Case Selection & Batching

Analytics-driven selection and batch optimization to concentrate effort where the economics justify it.

02

Financial Modeling & Valuation

Economic valuation, payment benchmarking, and expected-value modeling for each candidate dispute.

03

Market Reimbursement Analysis

Market rate and historical award analysis that frame a defensible offer against comparable data.

04

Evidence & Narrative Development

Structured evidence packages and a persuasive narrative aligned to the factors decision-makers weigh.

05

Clinical & Coding Integrity

Medical-necessity support, clinical justification, and coding integrity that withstand scrutiny.

06

Venue & Timing Strategy

Pathway, venue, and timing optimization so each dispute moves through the right process efficiently.

Internal Program Development

Most organizations never built an operating model

Many struggle with the NSA because they never designed an internal operating model for it. Fulcrum builds the governance, workflows, technology, and reporting that turn dispute resolution into a repeatable, high-performing program.

Governance & Operations
  • Organizational governance
  • Policies & SOPs
  • Escalation workflows
  • Staff training
  • Technology integration
  • Vendor management
  • Compliance monitoring
  • Quality assurance
Performance & Reporting
  • Executive dashboards
  • Performance metrics
  • Financial forecasting
  • Revenue reporting
  • Leadership reporting
  • Recovery analytics
  • Timeline compliance
  • Program scalability
Technology & Analytics

Every decision, backed by data

From federal eligibility to award recovery, Fulcrum instruments the entire program. Explore a sample dashboard view.

IDR Award Rate · By SpecialtyLive Sample
Award Rate (%)
Ranked Detail

Illustrative sample dashboards. Fulcrum analytics are built from your actual eligibility, submission, and award data — and can be modeled on your existing Power BI reporting.

Provider Specialties We Support

Depth across the out-of-network landscape

The NSA lands hardest on hospital-based and facility-based specialties. Fulcrum supports the full range of provider types and organizations.

Emergency MedicineRadiologyAnesthesiologyPathologyHospitalistsCritical CareTraumaGeneral SurgeryOrthopedicsNeurosurgeryPlastic SurgeryENTCardiologyBehavioral HealthAir AmbulanceNeonatologyWomen's HealthPhysician GroupsHospitalsHealth SystemsAcademic Medical CentersSurgery Centers
Health Plan Advisory

Trusted on both sides of the reimbursement ecosystem

Fulcrum differs from traditional arbitration firms: we also advise health plans and TPAs on building compliant, efficient internal NSA programs — bringing the same rigor to either side of the table.

Provider Side

Optimize out-of-network reimbursement

Enterprise NSA programs, federal and state IDR strategy, evidence and case selection, and analytics that maximize appropriate recovery.

  • Winning IDR strategy & evidence development
  • Case selection, batching & venue strategy
  • Revenue cycle integration & recovery analytics
  • Executive governance & reporting
Why Fulcrum

Not a law firm. Not an arbitration vendor.

A strategy-and-operations advisor with deep NSA specialization — combining former national program leadership, federal and state expertise, and analytics-driven execution.

Deep executive experience

Senior leaders who ran enterprise NSA programs.

Former national NSA leaders

Helped operationalize the law at national scale.

Federal & state expertise

Fluency across every dispute-resolution pathway.

Analytics-driven strategy

Data behind case selection, valuation & evidence.

Operational consulting

We design the operating model, not just advise.

Reimbursement specialists

Healthcare reimbursement is our entire focus.

Enterprise implementation

Scalable operating models built to grow.

Provider-first perspective

Built around the realities providers face.

Health plan advisory

Credible experience on both sides of the table.

Executive-level reporting

Board-ready visibility into program performance.

Scalable operating models

Repeatable governance and workflow at any size.

Nationwide capabilities

Federal and multi-state coverage, coast to coast.

The Difference

Beyond filing cases

Law Firms · Arbitration Vendors · RCM Consultants
Fulcrum Health Partners
Files individual IDR cases
Builds the enterprise NSA operating model
Reacts to each dispute
Designs governance, workflows & analytics up front
Legal interpretation only
Regulatory intent plus provider financial reality
Single-pathway focus
Federal, state, and hybrid pathway governance
Provider or payer only
Advises both providers and health plans
Thought Leadership

Regulatory intelligence, translated

NSA updates, IDR strategy guides, and executive insights — a resource center built for leaders navigating out-of-network reimbursement.

Illustrative Outcomes

Operational transformation, not guaranteed awards

We build strategic capability and sustainable programs. The outcomes below reflect the kind of operational transformation clients pursue — not a guarantee of arbitration results.

Accelerated workflows

Faster, more consistent movement of disputes from eligibility through determination.

Greater NSA readiness

Increased organizational readiness for federal and state compliance obligations.

Better case selection

Improved consistency in case selection and evidence development across teams.

Executive visibility

Enhanced governance and board-level visibility into program performance.

Scalable operating models

Programs designed to support organizational and transaction-driven growth.

Cross-functional alignment

Better alignment between legal, clinical, revenue cycle, and contracting teams.

Today's Challenges. Tomorrow's Solutions.

Navigate the No Surprises Act With Confidence.

Whether you are establishing an enterprise-wide NSA program, optimizing IDR performance, or strengthening compliance across federal and state frameworks, Fulcrum delivers the strategic expertise, operational discipline, and reimbursement insight to build a sustainable, high-performing program.