Introducing the Turquoise Out-of-Network Dashboard

Even if you’ve only been peripherally aware of the world of the No Surprises Act (NSA), you’re probably familiar with challenges stemming from out-of-network (OON) pricing or the Qualified Payment Amount (QPA). We don’t have to do much convincing when we tell you the federal Independent Dispute Resolution (IDR) process is expensive, slow, and structurally broken. 

If you are new or catching up, we’ll let the numbers do the talking: millions of IDR disputes have been filed since April 2022, far outpacing the initial government projection hundredfold. A backlog that was supposed to resolve itself within the first few quarters of activity has persisted for years. So if payers and providers as the primary parties involved in OON claims payments cannot effectively manage the QPA and IDR process without relying on third party involvement, the process as designed isn’t working as intended.

Following the Money

The administrative cost of the IDR process alone should give everyone pause. The current administrative fee is $115 per party per dispute, so we’re looking at a combined $230 cost before a single arbitrator has looked into any specifics of the episode of care. On top of that, certified IDR entity fees for a single determination run $200 to $840, and for batched disputes, over $1,000. Those numbers balloon enormously when multiplied by the actual volume: 4.8 million disputes filed through the end of 2025. Studies estimate the IDR process cost is in the billions, to the tune of billions of dollars in fees and administrative costs

The numbers are on the rise, too. In the first half of 2025, administrative fees alone ran to nearly $600 million, which comes close to matching the entire three-year total from 2022 through 2024. No additional Federal IDR Public Use Files have been released to show if that trend continued through the end of the year and into 2026, so it’s unclear if efforts to alleviate the IDR queue have been effective.

Transparent Root Cause Analysis

At Turquoise, we've watched all of this unfold, and, as we often do, we’ve asked what can be done to make the process more transparent. As it stands today, the QPA remains the breeding ground for dysfunction for a number of reasons:

• Plans calculate it internally
• Providers and arbitrators distrust those internal calculations, sometimes due to a the inclusion of claims or other data sources
• Open negotiation fails because the spread between what plans offer and what providers expect is too wide to close in 30 days. That also assumes good faith negotiations occur within that window of time, which isn’t always the case.
• Disputes flow into IDR at unsustainable volumes

And so the cycle repeats, which causes our ears to perk up as we look for ways to create more efficient healthcare transactions. Without a consistent QPA calculation that’s grounded in market rate data, there's no shared, neutral starting point. The ripple effect of a traceable payment amount would lead to more order out of the downstream chaos as well.

There are elements of the process laid out within the NSA, such as the baseball-style negotiation period surrounding the QPA, that generally led to misaligned incentives. Plus, the fact that the QPA, with its complex math that is difficult for providers to replicate if calculated within a payer-specific system, adds an element of opacity.

That QPA, which at a high level is meant to serve as a proxy for an in-network payment equivalent, benefits from increased transparency around how it’s calculated relative to market rates. Thus, knowing and trusting market rates is a foundational step towards creating a better process. Fortunately, the industry has experienced recent advances in payer MRFs thanks to the Transparency in Coverage (TiC) schema changes that went into effect on 2/1/26. With additional TiC proposed rule to be finalized later this year, payer MRF quality will only continue to improve.

Price Transparency Data & the QPA

The NSA itself allows for QPAs to come from an eligible database should a payer need sufficient information:

"means such rate for such item or service determined by the sponsor or issuer, respectively, through use of any database that is determined, in accordance with rulemaking described in paragraph (2)(B), to not have any conflicts of interest and to have sufficient information reflecting allowed amounts paid to a health care provider or facility for relevant services furnished in the applicable geographic region (such as a State all-payer claims database)

This is a welcome use case for current payer MRF data that’s been parsed to exclude clinically implausible rates. Parsing payer MRFs has been in our wheelhouse for a number of years now, so today, we're putting that data to more good use. 

The Turquoise OON Dashboard

Turquoise has launched a free, open license OON dashboard built on TiC MRF data. Within the dashboard, users can view Fair Market Bands to study how QPA and IDR awards compare to actual contracted market rates.

The OON dashboard also includes an OON pricer, which is designed for every stakeholder in the ecosystem interested in a public rate for a specific service with verifiable inputs and outputs:

• State regulators running their own IDR-type processes. Having a free, auditable alternative to claims-based benchmarks referenced in the NSA can ease the administrative burden for states like Georgia, Texas, New York, and others who manage their own version of an OON dispute queue. Price transparency data is significantly more meaningful than an all-payer claims database, since it does not contain PHI and is thus more granular and traceable. 
• Providers treating OON patients. These providers can validate or contest QPAs before languishing in the IDR process.
• Payers adjudicating and issuing QPAs. Payers can benchmark their internal calculations against independently verifiable market data, reducing exposure to disputes and the admin costs that come with them.
• IDR entities. These neutral third parties would thus have an independent reference point to assist with dispute resolution.
• Researchers and journalists have access to the [Need to update with name] page to monitor the public evidence of when QPAs diverge from market reality and when they are a true representative of the cost of care.

Why free? Why open license?

Our mission is to eliminate the financial complexity of healthcare. Minimizing the unintended administrative costs and drain on resources necessary for the current IDR process and paving the way for more streamlined OON payment processes is a direct tie to that mission.

Every dispute that settles in the 30-day open negotiation window because both sides trusted the number is a win for all parties involved: the provider, the payer, the no-longer-necessary IDR entity. We're not interested in monetizing friction or waiting for policy to catch up to the QPA opacity. We're interested in transparent solutions, and, in this case, we believe the OON pricer is a public good. Anyone can examine how the numbers are derived, stress-test the inputs, and verify the outputs. That's the type of transparency the healthcare transaction can and should have.

What comes next

The IDR process will continue to generate headlines, since there are lawsuits still pending and proposed rules still unfinalized. We'll be watching all of it. In the meantime, we believe public utility of the Fair Market Band and the OON pricer can provide a solution that consistently produces trustworthy QPAs and demonstrably reduces the volume of claims reaching IDR. We want that data to become part of the policy conversation on its own terms.