Federal IDR Operations Final Rule

On June 4, 2026, the Departments of Health and Human Services, Labor, Treasury, and the Office of Personnel Management (the “Departments”) issued Federal Independent Dispute Resolution (“IDR”) Operations Final Rules (“Final IDR Rule”). The Final IDR Rules improve the functioning of the Federal IDR process by streamlining communications between payers, providers, and certified IDR entities and clarifying timelines and processes.

Highlights

Reduced Administrative Fee. Effective June 11, 2026, the Federal IDR Administrative Fee amount is reduced to $15.00 per party per dispute from $115.00 per party per dispute. The Administrative Fee for disputes initiated on or after January 22, 2024, but before June 11, 2026, remains $115.00 per party per dispute.
New IDR Registry. Plans and payers subject to the Federal IDR process must register with the Departments through a new IDR Registry. Upon submission of this information, the plan or issuer will receive an IDR registration number to be used on IDR submissions. Effective Date: 90 days after new portal guidance.
Batching. The Departments are finalizing changes to the batching requirements, which allow multiple items or services as separate payment determinations in a single dispute to minimize costs for disputing parties, including a limitation to batched determinations of 50 qualified IDR items and services (or line items) in a single dispute. Effective Date: September 2, 2026 (90 days after June 4, 2026, publication date).
Communication Codes. Payers are required to communicate information to providers using claim adjustment reason codes (“CARCs”) and remittance advice remark codes (“RARCs”) for paper or electronic remittances. These codes reflect detailed information regarding the status of the claim. The Departments intend to issue future guidance to implement the CARC and RARC provisions of the Final IDR Rules. Effective Date: August 3, 2026 (60 days after June 4, 2026, Final Regulations publication date).
Open Negotiation. A party must provide an Open Negotiation Notice to the other party and the Departments through the Federal IDR Portal to initiate the Open Negotiation Period. The plan or TPA must submit a formal Open Negotiation Response Notice through the Federal IDR portal by the 15th business day of the 30-business-day Open Negotiation Period. The response must include the plan’s preferred certified IDR entity (in the event negotiation fails) and any conflict-of-interest disclosures. Effective Date: 90 days after additional guidance is issued.
IDR Eligibility Determinations. The Final IDR Rule codifies the authority of the selected certified IDR entity to request additional information from either party, at any time, to determine NSA claim eligibility within 5 days of request. The applicable IDR process timeframe is tolled from the date of the request until the earlier of: (i) receipt of all requested information, or (ii) expiration of the 5-business-day period. Failure to respond timely could cause the issuance of a default award to counterparty. Effective Date: 90 days after additional guidance is issued.
Extenuating Circumstances. The Departments are finalizing a revision to the types of extenuating circumstances which may extend the IDR process time periods, including events that contribute to systematic delays in processing disputes under the IDR process, such as an unforeseen volume of disputes or IDR portal system failures. Parties may also continue to request extensions through the IDR portal. Effective Date: 90 days after the necessary portal changes.