With over 28 years of experience at the intersection of healthcare, pharmacy, and law, Structural Dispute Resolution speaks the language of providers, payers, and counsel — bringing technical fluency to every negotiation and hearing.

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Providing balanced, efficient resolution for court-ordered and voluntary civil matters, Structural Dispute Resolution serves litigants, insurers, and counsel across a broad range of disputes — with the same rigorous, neutral approach applied to every matter regardless of size or complexity.

Don't see what you're looking for? Feel free to reach out — we're happy to discuss your matter directly.

In complex healthcare disputes, the mediator's ability to evaluate clinical causation arguments, regulatory compliance positions, and financial exposure simultaneously is often the difference between impasse and resolution. Charles F. Manning's unique background eliminates the need for extensive expert translation — he arrives at the table already fluent in the technical language of every stakeholder in the room.

Risk, Leverage, and Settlement Architecture in Medical Malpractice, Personal Injury, and Complex Healthcare Disputes

All travel expense determinations are based on distance from Bentonville, Arkansas (mediator's home base). Remote sessions (video/telephone) incur no travel charges. In-person sessions are subject to the following policy:

From initial contact to final resolution, Structural Dispute Resolution is designed to be efficient, transparent, and professionally managed at every step.

Reach out by phone or email with a brief description of your dispute. Charles F. Manning personally reviews every inquiry to confirm there is no conflict of interest, assess the nature of the matter, and recommend the appropriate service tier and session format — remote or in-person.

Once scheduling is confirmed, parties are invited to submit relevant documents, correspondence, or a short written summary of their position. This step is optional but strongly recommended — reviewing the underlying facts in advance allows session time to focus on substantive negotiation rather than background explanation, and often shortens the overall time to resolution.

Sessions open with all parties present, followed by joint discussion and private caucus as needed. Charles F. Manning facilitates communication, helps identify the actual points of disagreement, and tests potential settlement structures — drawing on both legal and, where relevant, clinical or regulatory expertise to move the conversation forward.

Healthcare disputes rarely resemble standard commercial conflicts. A payer-provider disagreement, a PBM contract dispute, or a malpractice claim carries layers most general mediators aren't equipped to navigate — regulatory exposure under HIPAA or the No Surprises Act, clinical causation questions, and financial structures unique to healthcare reimbursement.

Many healthcare disputes carry compliance implications that extend beyond the immediate dollar amount at stake. A billing dispute may touch False Claims Act exposure; a data-sharing disagreement may implicate HIPAA. A mediator without healthcare-specific fluency may miss these dimensions entirely, leaving parties to negotiate blind to real risk.

In malpractice and clinical liability disputes, executives often conflate "was this the right medical decision" with "what is our legal and financial exposure." These are related but distinct questions. A mediator who can evaluate clinical causation directly — rather than relying entirely on expert reports — can help parties see where genuine disagreement exists versus where positions are simply entrenched.

Healthcare disputes often involve multiple cost variables — settlement amount, ongoing contract terms, corrective action commitments, confidentiality provisions. Walking into mediation with a clear internal understanding of which variables are flexible and which are fixed dramatically shortens the path to resolution.

A common misconception is that entering mediation signals weakness or forecloses other options. It does neither. Mediation is confidential and non-binding unless a settlement is signed — if the matter doesn't resolve, every other legal option remains fully available, and nothing said during the session can be used as evidence later.

Pharmacy benefit manager (PBM) contract disputes have become one of the most contentious and financially significant categories of healthcare conflict — spanning reimbursement rate disagreements, network participation terms, claims adjudication conflicts, and audit findings. For pharmacies, health systems, and PBMs alike, litigation is often the default path considered, but rarely the most efficient one.

Reimbursement formulas, MAC pricing disputes, DIR fee disagreements, and audit clawback claims require someone who can actually parse the underlying pharmacy economics — not just the contract language. Litigation typically requires both sides to retain expert witnesses to explain these mechanics to a judge or jury unfamiliar with pharmacy operations. Mediation with a mediator who already understands this terrain eliminates that translation layer entirely, often saving substantial time and expert witness cost.

Many PBM contract conflicts involve ongoing business relationships — a pharmacy still filling claims under a disputed contract, or a health system still processing claims through a PBM it's simultaneously disputing. Litigation can take 18 months to several years to resolve. Mediation can produce a resolution — or at minimum, meaningful clarity — in a single session or a short series of sessions.

Contract terms, reimbursement rates, and audit findings in the PBM space are often treated as closely guarded competitive information. Litigation is a matter of public record; mediation is confidential. For parties concerned about competitors or other counterparties learning the specifics of a contract dispute, this distinction alone can be decisive.

Many PBM-pharmacy or PBM-health system relationships are ongoing and mutually necessary — network participation isn't easily replaced. An adversarial litigation process can permanently damage a relationship that both sides need to continue. Mediation's collaborative structure is far more likely to produce an outcome both parties can continue working within.

Not every malpractice claim is ready for mediation the moment it's filed. Understanding what actually makes a case 'mediation-ready' — and what a mediator with clinical training brings to that readiness — can help both plaintiff and defense counsel time the process more effectively.

Parties often wait until discovery is fully closed before considering mediation, assuming more information always produces better settlement odds. In practice, mediation is often most productive once the core medical records, expert opinions on standard of care, and causation theories are established — even if peripheral discovery is ongoing. Waiting for complete discovery frequently means waiting through months of expense that mediation could have shortened.

In most malpractice mediations, the mediator relies entirely on the parties' competing expert reports to understand the clinical dispute, without independent ability to assess whether either side's clinical position is actually strong. A mediator with direct pharmacy and clinical operations background can engage with causation and standard-of-care arguments more substantively — asking sharper questions, testing weaker positions more effectively, and helping both sides see where their clinical theory is genuinely strong versus where it depends on a favorable jury finding a close call in their favor.

Malpractice settlement valuation typically factors economic damages, non-economic damages, comparative fault exposure, and litigation cost avoidance — but healthcare-specific claims often carry additional variables: regulatory reporting obligations, potential licensure action, and reputational exposure for a facility or provider. A mediator who understands these dimensions can help parties see the full settlement calculus, not just the litigation verdict range.

Balance billing disputes arising under the federal No Surprises Act increasingly intersect with malpractice and facility liability claims, particularly in emergency and out-of-network care scenarios. These claims involve a federal arbitration framework parties may not be familiar with, and a mediator conversant in both traditional malpractice valuation and the newer No Surprises Act mechanics can help parties avoid pursuing an inefficient or procedurally mismatched resolution path.

Small claims, consumer debt, and landlord-tenant disputes rarely make headlines, and the dollar amounts involved are often modest compared to complex commercial litigation. But for the people involved — a tenant facing an unreturned security deposit, a small business owner chasing an unpaid invoice, a landlord dealing with a habitability dispute — these conflicts carry real financial and personal weight. Treating them with genuine process, rather than a rushed formality, produces better outcomes for everyone.

Commercial litigants are frequently represented by counsel and separated from the dispute by a corporate structure. Small claims and landlord-tenant matters usually involve individuals directly — often without attorneys, often emotionally invested, and often unfamiliar with the legal process itself. A mediator's ability to explain the process clearly, keep the conversation constructive, and ensure both sides genuinely feel heard matters more here, not less, because there's no buffer of institutional distance softening the interaction.

A security deposit dispute is frequently really about feeling disrespected or dismissed during the tenancy. A consumer debt dispute often involves a genuine disagreement about whether a service was performed adequately, not just whether an invoice is technically owed. Mediation allows these underlying issues to surface and be addressed directly — something a small claims court appearance, limited to a few minutes before a judge, structurally cannot accommodate.

Litigation costs — filing fees, potential attorney fees, time off work for court appearances — can easily exceed the amount actually in dispute for small claims matters. A streamlined, hourly-rate mediation session (often resolvable in a single hour) offers a proportionate, cost-effective path that matches the scale of the dispute, rather than forcing parties into a process designed for larger stakes.

Habitability claims, lease interpretation disagreements, and eviction-adjacent negotiations often involve two parties with genuinely competing practical pressures — a landlord managing a property as a business, a tenant navigating housing stability. Effective mediation in this space requires procedural fairness and genuine neutrality, not an assumption that one side's position is inherently more sympathetic than the other's.

Breach of contract claims, partnership disagreements, and vendor conflicts are among the most common disputes businesses face — and among the most frequently over-litigated. For most commercial disputes, mediation isn't a consolation prize before "real" litigation; it's often the more strategically sound first move.

Courts interpret contracts based on their written terms, but most contract disputes actually arise from a gap between what was written and what the parties genuinely expected. A vendor conflict over a "reasonable efforts" clause, or a partnership disagreement over unwritten understandings about roles and profit-sharing, often can't be fully resolved by a judge simply reading the four corners of the document. Mediation allows the underlying expectations — not just the literal contract terms — to be addressed directly, which is frequently where the real resolution lies.

A judge or jury can only award what the law and the pleadings allow — typically damages, sometimes specific performance. A mediated resolution can include terms a court could never order: a revised payment schedule, an amended contract term going forward, a phased wind-down of a business relationship, or a combination of monetary and non-monetary terms tailored to what each side actually needs. This flexibility is often the single biggest advantage mediation offers over litigation in commercial disputes.

Many commercial disputes — vendor relationships, joint ventures, long-term supply contracts — involve parties who would ideally continue working together after the dispute resolves, or at minimum need to wind down the relationship without lasting animosity. Litigation's adversarial structure tends to harden positions and damage relationships that mediation's collaborative framework is far more likely to preserve.

Business disputes frequently involve substantial document production, deposition costs, and expert testimony on damages calculations. For many contract and partnership disputes, the legal costs of reaching trial meaningfully erode — or exceed — the value actually in dispute. Mediation, particularly when pursued before extensive discovery, can preserve resources that would otherwise be spent proving a case rather than resolving it.

Property valuation disagreements — whether arising from insurance appraisal disputes, damages quantification in a civil claim, or disputed property value in a broader dispute — share a common structural problem: both sides typically arrive with their own expert appraisal, each professionally prepared, each reaching a different number, and often little room for genuine agreement built into the process.

Two qualified appraisers can reach substantially different valuations not because either is wrong, but because they've applied different methodologies, weighted different comparable properties, or made different assumptions about condition, market timing, or scope of damage. Litigation typically resolves this by having a judge or jury choose between two competing experts — a binary outcome that doesn't actually reconcile the underlying methodological disagreement, it just picks a winner.

Rather than treating valuation as a single number to fight over, a mediated process can walk through where the two appraisals diverge — comparable property selection, condition assessments, market adjustments, scope of repair — and identify which specific inputs are genuinely disputed versus where there's more agreement than the headline numbers suggest. This often narrows what initially looks like a wide gap into a much smaller, more resolvable range.

Many property insurance policies include appraisal clauses with specific procedural requirements — separate from litigation — for resolving disputed claim values. Understanding how these appraisal provisions interact with broader settlement negotiation, and where mediation fits alongside or instead of the formal appraisal process, can materially affect how efficiently a claim resolves.

When both sides are anchored to their own expert's number, movement can stall simply because acknowledging the other side's figure feels like conceding the case. A mediator who can engage substantively with valuation methodology — not simply split the difference between two numbers — helps both sides test their own appraisal's assumptions as rigorously as they're testing the other side's, which is often what actually unlocks movement toward resolution.