Federal IDR Operations Final Rule Released
On May 28, 2026, the Department of Health and Human Services, along with the Department of Labor and Department of Treasury, issued a final rule amending the Independent Dispute Resolution (IDR) process under the No Surprises Act (NSA).
These changes will have direct implications for all providers covered under the NSA, including air ambulance.
In particular, the key changes to the IDR process include:
A Reduced Administration Fee from $115.00 per party to $15.00 per party, making IDR a more viable option for smaller-dollar disputes.
Standardized Federal IDR Portal: Open negotiation notices and responses will go through a federal IDR portal using standard forms, cutting out the payer-specific portal requirements that caused delays and further disputes.
Required Payer Registration: Plans and issuers must register in the federal IDR system, which should improve transparency and help providers identify the right responsible payer.
Expanded Payer Disclosures: Standardized remittance coding plus more detail on NSA applicability, qualified payment amount (QPA) calculations, batching eligibility, and cost-sharing.
Clearer & More Flexible Batching Rules: Qualified IDR items and services may be batched under the following circumstances:
Items and services are furnished to a single patient on the same, or consecutive, dates of service and billed on the same claim form (a patient encounter).
Items and services are furnished to one or more patients and are billed under the same service code or a comparable code under a different procedural code system (e.g., CPT and HCPCS).
Anesthesiology, radiology, pathology, and laboratory items and services are furnished to one or more patients under service codes belonging to the same Category I CPT code section.
The Departments have also limited batched determinations to 50 qualified IDR items and services in a single dispute to ensure certified IDR entities can make timely eligibility and payment determinations while reasonably forecasting and covering their costs.
Earlier Eligibility Review: More claim-level information will be required upfront to reduce downstream dismissals.
More Extension Flexibility: Additional flexibility is available for portal outages, technical failures, natural disasters, and other unforeseen events.
What Do These Changes Mean for Providers?
The overall intent of the final rule is to address the backlog, procedural confusion, and inefficiencies of the Federal IDR process.
The changes are designed to improve functionality by streamlining communication between payers, providers, and certified IDR entities while clarifying timelines and processes.
See CMS's outline of the Federal Independent Dispute Resolution Operations Final Rule.
Determining the Correct IDR Pathway
One of the most effective ways for providers to navigate the IDR process is to first determine whether a claim is governed by state or federal law, as that distinction determines which dispute resolution pathway applies.
Solutions Group's ERISA Determinant tool helps streamline that process by using AI-powered technology and proprietary scrubbing automation to identify indicators of plan type, including whether coverage may be self-funded or fully insured.
By establishing the appropriate reimbursement pathway earlier, providers can reduce administrative burden and improve efficiency throughout the dispute lifecycle.
Contact us today at connect@solutionsgroup.com to learn more.
By Alexandra Hembrough, Esq., General Counsel, Solutions Group Services