POLICY ANALYSIS | May 2026
Eliott Dear: The Hidden Cost of Carrier-Internal Data — Why State IDR Looks to FAIR Health
By Eliott Dear, Esq.
Every out-of-network claim arrives with a number the carrier chose. The carrier computes it from its own data, makes its own methodology choices, and checks its own work.
Eliott Dear watches the consequences play out daily on Claims Assassins filings. The structural problem is worth naming clearly.
What the Carrier’s Number Is
A carrier’s own figure is built from its own contracts, its own claims history and its own methodology. It shows up looking official: a single figure on the EOB, presented as what the procedure is worth.
Looking official and being independent are two different things.
The Carrier-Computes-Carrier-Audits Loop
Each carrier computes its own figure per CPT per geographic locality, internally, using its own data, its own methodology choices, and its own audit. Providers do not see the data. The number arrives on the EOB as a single figure with no audit trail.
That is the conflict of interest. The carrier writes the number that determines what the carrier owes. The carrier audits the carrier. When a provider challenges that number, the carrier still controls the underlying data the challenge attempts to attack.
Why It Leans One Way
A number built by the party that owes the money leans toward the party that owes the money. Every exclusion, every methodology choice, every judgment call inside the calculation is made by the carrier, on the carrier’s side of the table.
That is not a coincidence; it is the predictable consequence of the carrier-computes-carrier-audits loop.
Why It Persists
The loop persists because only the carrier holds the inputs. A provider cannot audit a dataset it cannot see, and the carrier has no reason to open one up.
So the loop continues. The structural conflict remains.
The State-Regulator Alternative
State IDR systems look to FAIR Health UCR data — data compiled by an independent nonprofit from billions of claims across multiple carriers. FAIR Health has its own methodology debates, but it does not have the conflict-of-interest problem of carrier-internal computation.
Eliott Dear and Claims Assassins file state IDR for exactly this reason: the benchmark is not the carrier’s own number.
Test one claim.
edear@edrtb.com | 646-387-9133 | Send one EOB. No contract. 10% of the improvement.
Get started →Eliott Dear is the founder and CEO of Claims Assassins (EDRTB LLC). Fordham Law School, Law Review. Formerly Clifford Chance LLP. NY Bar #4329546, active.