CPT 99221: Federal IDR outcomes
Initial hospital care with straightforward or low level of medical decision making, per day, if using time, at least 40 minutes
In 2025 Q1–Q4, the provider or facility offer prevailed in 81.3% of 827 determined Federal IDR dispute line items for CPT 99221. The median prevailing offer was 13.66x the QPA (25th–75th percentile 6.42x–23.84x; n = 791). The median time to a decision was 31 business days (n = 827).
Determined line items
827
2025 Q1–Q4 · 5 split decisions excluded
Provider win rate
81.3%
n = 827 · 2025 Q1–Q4
Median payment vs QPA
13.66x
middle half 6.42x–23.84x · n = 791 · 2025 Q1–Q4
Median days to decision
31
business days, from dispute initiation · n = 827 · 2025 Q1–Q4
Dollar amounts
Total awarded
$1.6M
sum of prevailing offers · n = 582 · 2025 Q1–Q4
Total QPA
$239,684
sum of QPAs, same line items · n = 582 · 2025 Q1–Q4
Awarded above QPA
$1.3M
total awarded minus total QPA · n = 582 · 2025 Q1–Q4
Median award per line item
$1,806
mean $2,712 · n = 582 · 2025 Q1–Q4
Median QPA
$132
per line item · n = 582 · 2025 Q1–Q4
Award vs QPA, dollar-weighted
6.58x
total awarded ÷ total QPA · n = 582 · 2025 Q1–Q4
Dollar amounts come from the separate CMS “QPA and Offers” file: line items decided for the provider or the plan with a non-suppressed QPA and prevailing offer. That file cannot be joined to the line items above, so its n differs. Awarded = the prevailing (selected) offer; it is not a record of what was paid. State comes from the file’s geographic region; a metro area that spans states counts in each. How the dollar figures work
Dollar amounts by period
| Period | Line items with $ | Total awarded | Total QPA | Above QPA | Median award | Median QPA | Award ×QPA ($-weighted) |
|---|---|---|---|---|---|---|---|
| 2025 Q1–Q4 | 582 | $1.6M | $239,684 | $1.3M | $1,806 | $132 | 6.58x |
| 2024 Q3–Q4 | 128 | $218,192 | $16,866 | $201,326 | $1,325 | $117 | 12.94x |
| 2024 Q3–2025 Q4 | 710 | $1.8M | $256,550 | $1.5M | $1,806 | $127 | 7.00x |
| 2023 Q1–2024 Q2 | Not available (see methodology). | ||||||
From the CMS QPA and Offers file (see above). Award ×QPA here is total awarded ÷ total QPA, so large claims weigh more than in the per-line median ratio.
By period
| Period | Line items | Win % | Median ×QPA | 25th–75th | Ratio n | Median days |
|---|---|---|---|---|---|---|
| 2025 Q1–Q4 | 827 | 81.3% | 13.66x | 6.42x–23.84x | 791 | 31 |
| 2024 Q1–Q4 | 282 | 77.0% | 7.47x | 3.16x–14.86x | 268 | 45 |
| 2023 Q1–Q4 | 80 | 66.2% | 2.00x | 1.05x–2.30x | 77 | 165 |
| 2023 Q1–2025 Q4 | 1,189 | 79.2% | 10.77x | 4.37x–20.58x | 1,136 | not pooled |
Line items = determined dispute line items (n). Win rate excludes split decisions and includes default decisions. Ratio n = line items reporting a payment-to-QPA ratio. Days are business days as reported by CMS (2023–2024: from IDR entity assignment; 2025: from initiation) and are never pooled.
By state
| State (place of service) | Line items | Win % | Median ×QPA | Ratio n | Median days |
|---|---|---|---|---|---|
| New Jersey | 309 | 79.3% | 14.40x | 300 | 36 |
| Texas | 163 | 86.5% | 12.16x | 152 | 29 |
| Arizona | 92 | 85.9% | 10.21x | 92 | 28 |
| California | 82 | 90.2% | 29.93x † | 81 | 27.5 |
| New York | 48 | 60.4% | 24.03x † | 46 | 26 |
2025 Q1–Q4 · rows with n ≥ 30 determined line items · sorted by n.
Dollar amounts by state
| State (region) | Line items with $ | Total awarded | Median award | Median QPA | Award ×QPA |
|---|---|---|---|---|---|
| New Jersey | 299 | $805,610 | $1,806 | $133 | 4.08x |
| New York | 299 | $805,610 | $1,806 | $133 | 4.08x |
| Pennsylvania | 299 | $805,610 | $1,806 | $133 | 4.08x |
| Texas | 80 | $179,933 | $3,500 | $147 | 15.88x |
| Arizona | 64 | $78,257 | $1,157 | $120 | 10.10x |
| California | 63 | $268,321 | $5,000 | $158 | 25.20x |
2025 Q1–Q4 · CMS QPA and Offers file · rows with n ≥ 30 line items with dollar amounts · sorted by n · Award ×QPA = total awarded ÷ total QPA.
By specialty
| Specialty group | Line items | Win % | Median ×QPA | Ratio n | Median days |
|---|---|---|---|---|---|
| General and other surgery | 262 | 81.7% | 14.40x | 260 | 34 |
| Emergency medicine and emergency departments | 180 | 83.3% | 15.43x | 171 | 29 |
| Internal and family medicine | 85 | 83.5% | 11.28x | 85 | 31 |
| Neurosurgery and spine surgery | 65 | 87.7% | 37.51x † | 60 | 30 |
| Radiology | 51 | 98.0% | 7.04x | 50 | 35 |
| Cardiothoracic and thoracic surgery | 33 | 51.5% | 32.56x † | 33 | 24 |
2025 Q1–Q4 · rows with n ≥ 30 determined line items · sorted by n.
Section: Evaluation and management (99202–99499)
FAQ
What is the Federal IDR provider win rate for CPT 99221?
In 2025 Q1–Q4, the provider or facility offer was selected in 81.3% of 827 determined dispute line items for CPT 99221. Split decisions are excluded from the denominator and default decisions are included. Withdrawn, settled and ineligible disputes are not in the CMS data.
How do Federal IDR payments compare with the QPA for CPT 99221?
In 2025 Q1–Q4, the median prevailing offer was 13.66x the qualifying payment amount (QPA), with a 25th to 75th percentile range of 6.42x to 23.84x (n = 791 line items). This uses the CMS field Prevailing Party Offer as % of QPA, where 1.00x equals the QPA.
How long do Federal IDR decisions take for CPT 99221?
In 2025 Q1–Q4, the median was 31 business days (n = 827 line items), using the CMS field Length of Time to Make Determination (from dispute initiation).