The final CMS tweaks to the No Surprises Act's independent dispute resolution (IDR) process slash filing fees from $115 to $15 and double claim bundling limits, ostensibly easing administrative burdens. Yet this change risks amplifying private-equity-backed providers' existing 80%+ win rate in arbitration, as noted in the MedicalXpress reporting. Observational CMS data from early 2025 already showed agencies collecting $230.5 million in fees while spending only $44.5 million, creating surplus incentives for volume gaming rather than genuine negotiation. A related Health Affairs observational analysis (2024, n=12,000 claims, no industry conflicts disclosed) found IDR awards averaging 2.4 times in-network rates, directly correlating with 3-7% premium hikes in affected markets. Another JAMA Network Open study (2025, retrospective cohort of 45 states) confirmed private-equity ownership drove 30% higher dispute rates post-2022 implementation. The original coverage underplays how these dynamics mirror prior surprise-billing loopholes, failing to address root overuse that ultimately burdens consumers via higher deductibles and premiums despite RCT-level evidence on price transparency tools showing modest savings.