Q3 2025 Health Insurance Payer-Provider Dispute Update
The third quarter of 2025 continued to be dynamic for the healthcare industry, driven by evolving regulatory and legislative shifts impacting organizations across the sector. Early actions taken at the start of the Trump administration are taking effect, prompting payers and providers to adjust their operational, policy and regulatory strategies as they adapt to new pressures and emerging opportunities.
In the very first week of the quarter, President Trump signed the One Big Beautiful Bill Act of 2025 (“OBBBA”) into law, cutting gross Medicaid and Children’s Health Insurance Program funding by $990 billion over the next decade.1 The Congressional Budget Office projects that 16 million Americans will lose coverage and become uninsured as a result of the OBBBA alongside the current legislative landscape.2 This increase in the number of uninsured patients seeking care will continue to put pressure on providers, hospitals, health systems and payers as they prepare for a significant loss of members enrolled in comprehensive health insurance coverage.3
The new law is also expected to impact the Medicare program by reducing reimbursement rates that could limit supplemental benefits, increase out-of-pocket cost sharing for seniors and lead to narrower provider networks.4 These financial and regulatory pressures are contributing to a contraction in the Medicare Advantage (“MA”) marketplace, as some MA plans exit markets, and providers limit the number of MA plans with which they contract.5 These dynamics are contributing to an increase in payer-provider disputes in MA, creating instability and disrupting care for the growing number of seniors receiving their insurance through MA.6 As open enrollment begins for 2026, these policy-driven shifts are reshaping the MA landscape, with seniors facing fewer plan choices and more limited access to in-network providers, raising concerns about continuity of care and the impact on seniors’ health and health outcomes.7
These issues, among others reported in our quarterly updates, have contributed to the growing number of payer-provider disputes observed in Q3, compared to the first half of the year.
For three years, FTI Consulting’s Healthcare Strategic Communications team has tracked and reported on payer-provider disputes through publicly-reported news coverage and paid and earned media. Reaching agreement on key contract terms—such as reimbursement, utilization management, care coordination, disease management, quality improvement and performance metrics—has become increasingly challenging, affecting coverage for tens of millions of individuals and families across the United States.8 Contract negotiations that result in disputes continue to draw attention from state and federal policymakers, regulators and local government officials, with growing visibility and coverage across traditional and social media outlets and the public.9
What we found: Among all quarterly updates since 2022, Q3 2025 reported the third-highest number of reported disputes.
Q2 2025 Healthcare Quarter in Review
- In Q3 2025, there were a total of 36 disputes reported in traditional media outlets, 22 of which remain unresolved.
- Of the 36 total reported disputes, 47% (17) involved MA plans and 11 of those went unresolved by the end of the third quarter.
- Q3 and Q4 of 2024 included the highest number of publicly reported disputes –37 and 50, respectively.
OON = Out of Network
As contract negotiations and disputes continue to draw scrutiny from policymakers, the public and the media, a growing number of national healthcare trade publications and top-tier media outlets are reporting on payer-provider conflicts and the underlying factors driving them. In Q3, FTI Consulting’s data was featured in POLITICO, Modern Healthcare, and Healthcare Dive, indicating that although coverage of local and regional contract negotiations and disputes continues to rise, national media and healthcare trade publications are now increasingly drawing attention to these conflicts and their broader implications for individuals and families nationwide.
Looking Ahead – Medicaid and the ACA in the Spotlight
Beyond its effect on uninsurance rates, the OBBBA is expected to have a significant impact on Medicaid through changes to eligibility requirements and funding reductions.10 As many as 7.5 million Americans could lose Medicaid coverage as a result of the changes.11 Regional health plans—which have traditionally provided more stable and consistent access to health insurance coverage for individuals enrolled in government-sponsored programs (e.g., Medicaid, Medicare, Affordable Care Act (“ACA”) marketplace plans)—are likely to face increased costs and declining membership.12 These pressures may contribute to a rise in regional disputes.
Public policymakers at the federal and state levels continue to be divided on other aspects of the ACA, including the Premium Tax Credit.13 Debates around Premium Tax Credits from the ACA have contributed to the government shutdown.14 With the impacts of the shutdown and the implementation of the OBBBA, these trends are likely to persist into the fourth quarter and beyond.
Research Methodology: FTI Consulting searched multiple news databases for articles regarding negotiations over reimbursement rates between provider organizations and insurance companies. Those negotiations that were publicly reported by a news outlet on or after July 1 were counted for the quarter in which they were reported. Negotiations that were resolved or failed to reach an agreement in one quarter but were first reported in another quarter were counted for the quarter in which they became public. Where providers no longer accept any MA plans, FTI Consulting has counted that decision as a single dispute.
Related Practices
[1] Park, Edwin et al., “Medicaid, CHIP, and Affordable Care Act Marketplace Cuts and Other Health Provisions in the Budget Reconciliation Law, Explained,” Georgetown University McCourt School of Public Policy Center for Children and Families (July 22, 2025), https://ccf.georgetown.edu/2025/07/22/medicaid-chip-and-affordable-care-act-marketplace-cuts-and-other-health-provisions-in-the-budget-reconciliation-law-explained/#:~:text=On%20July%204%2C%202025%2C%20President.
[2] “Estimated Effects on the Number of Uninsured People in 2034 Resulting From Policies Incorporated Within CBO’s Baseline Projections and H.R. 1, the One Big Beautiful Bill Act,” Congressional Budget Office (June 4, 2025), https://www.cbo.gov/publication/61463.
[3] “Fact Sheet: One Big Beautiful Bill Act Would Significantly Reduce Availability of Coverage in the Health Insurance Marketplaces,” American Hospital Association (June 4, 2025), https://www.aha.org/fact-sheets/2025-06-05-fact-sheet-one-big-beautiful-bill-act-would-significantly-reduce-availability-coverage-health-insurance.
[4] Neuman, Tricia et al., “What Could the Health-Related Provisions in the Reconciliation Law Mean for Older Adults?” KFF (September 17, 2025), https://www.kff.org/medicare/what-could-the-health-related-provisions-in-the-reconciliation-bill-mean-for-older-adults/.
[5] Hooper, Kelly et al., “Medicare Advantage stands on wobbly legs,” Politico (September 29, 2025), https://www.politico.com/newsletters/politico-pulse/2025/09/29/medicare-advantage-stands-on-wobbly-legs-00583827.
[6] Casolo, Elizabeth, “Big MA market exits are not fazing all insurers,” Becker’s Payer Issues (October 1, 2025), https://www.beckerspayer.com/payer/medicare-advantage/big-ma-market-exits-are-not-fazing-all-insurers/.
[7] Ives-Rublee, Mia et al., “The Truth About the One Big Beautiful Bill Act’s Cuts to Medicaid and Medicare,” Center for American Progress (July 3, 2025), https://www.americanprogress.org/article/the-truth-about-the-one-big-beautiful-bill-acts-cuts-to-medicaid-and-medicare/.
[8] Hudson, Caroline, “Provider, payer contract disputes are heating up,” Modern Healthcare (May 29, 2024),-. https://www.modernhealthcare.com/providers/health-plan-negotiations-inflation-claims-denials/#:~:text=Contract%20negotiations%20are%20growing%20more,from%20the%20COVID%2D19%20pandemic.&text=Providers%20are%20facing%20higher%20costs,agreeing%20on%20how%20much%20higher.%E2%80%9D.
[9] Emerson, Jakob, “Payers, providers diverge on why No Surprises costs are climbing,” Becker’s Payer Issues (October 13, 2025), https://www.beckerspayer.com/payer/payers-providers-diverge-on-why-no-surprises-costs-are-climbing/.
[10] “Health Provisions in the 2025 Budget Reconciliation Law,” KFF (August 22, 2025), https://www.kff.org/medicaid/health-provisions-in-the-2025-federal-budget-reconciliation-law/#2ca666ac-5d15-4454-8973-241566e22bb5–h-eligibility-and-cost-sharing-policies.
[11] Emerson, Jakob, “Most regional payers are operating at a loss: 5 notes,” Becker’s Payer Issues (September 25, 2025) https://www.beckerspayer.com/financial/most-regional-payers-are-operating-at-a-loss-5-notes/.
[12] Ibid.
[13] Hooper, Kelly et al., “Breaking down the ACA subsidy fight,” Politico (October 2, 2025), https://www.politico.com/newsletters/politico-pulse/2025/10/02/breaking-down-the-aca-subsidy-fight-00590901.
[14] Swenson, Ali, “Health care subsidies are at the heart of the shutdown fight. Here’s who loses if they expire,” PBS News (October 16, 2025), https://www.pbs.org/newshour/politics/health-care-subsidies-are-at-the-heart-of-the-shutdown-fight-heres-who-loses-if-they-expire.
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