Process Guidance
IDR Initiation & Claim Batching
How to initiate the Federal IDR process within the 4-day window, select an entity, and properly batch similar claims to reduce administrative fees.
When open negotiation concludes without an agreement, the initiating party must move swiftly to escalate the dispute. The Federal IDR initiation phase dictates who will decide the payment amount and requires strict adherence to tight deadlines.
1. The 4-Business-Day Initiation Window
If the 30-business-day open negotiation period ends without a resolution, you have exactly 4 business days to initiate the Federal IDR process through the official CMS portal.
The initiation notice must include the preferred certified IDR entity, information to identify the items or services in dispute, and an attestation that the items or services are eligible for the Federal IDR process.
2. Selecting a Certified IDR Entity
The initiating party proposes a certified IDR entity in their initiation notice. The non-initiating party has 3 business days to either agree or object and propose an alternative. If the parties cannot agree, the Departments will randomly assign a certified IDR entity. Ensure your chosen entity does not have a conflict of interest.
3. Administrative and Entity Fees
Both parties must pay a non-refundable administrative fee to participate in the IDR process. Additionally, both parties must submit the certified IDR entity fee. However, only the losing party ultimately pays the entity fee; the winning party's entity fee is refunded within 30 business days of the determination.
Batching Claims to Reduce Costs
To minimize administrative burden and fees, multiple qualified IDR items or services can be "batched" into a single dispute if they meet strict criteria:
- Billed by the same provider or facility (same NPI/TIN).
- Paid by the same health plan or issuer.
- Involve the same or similar items or services (typically identical Service Codes).
- Occur within a 30-business-day period (or alternative timeline as permitted by the Departments).
Improper batching is a common reason for dispute rejection. Ensure all batched claims strictly adhere to the similarity and temporal requirements before submitting them as a single dispute.