Operational Reference Tool

Federal IDR Deadline & Records Matrix

A comprehensive, printable matrix of every No Surprises Act Federal IDR deadline, triggering event, and required documentation.

Accountability & Review

Reviewed by Millennova Legal Operational Integrity Team, Senior Audit and Arbitration Analysts

Last Reviewed

15 September 2026

Phase	Triggering Event	Regulatory Deadline	Required Operational Record
Initial Payment or Denial	Submission of a clean claim by the provider	30 calendar days From the date the plan receives the clean claim.	Initial Payment/Notice of Denial, EOB/ERA, and QPA Disclosure.
Initiate Open Negotiation	Receipt of initial payment or notice of denial	30 business days From receipt date.	Standard Open Negotiation Notice and proof of delivery/receipt.
Open Negotiation Period	Submission of the Open Negotiation Notice	30 business days Duration of the negotiation period.	Log of all offers, counteroffers, and related correspondence.
Initiate Federal IDR	Exhaustion of the 30-business-day open negotiation period without agreement	4 business days Following the end of the negotiation period.	Notice of IDR Initiation (via CMS portal) proposing a certified IDR entity.
IDR Entity Selection	Receipt of the Notice of IDR Initiation	3 business days For the non-initiating party to object or agree.	Notice of agreement or alternative entity proposal.
Submit Final Offers	Selection/assignment of the certified IDR entity	10 business days From the date the entity is finalized.	Notice of Offer, final requested payment amount, and indexed evidentiary packet (acuity, QPA disputes, etc.).
Payment Determination	Selection/assignment of the certified IDR entity	30 business days For the entity to issue a binding determination.	Written decision from the certified IDR entity.
Final Payment	Issuance of the binding IDR determination	30 calendar days From the determination date.	Remittance advice reflecting the final determined amount.

Disclaimer: This matrix provides general federal timeframes for operational reference. Actual deadlines may vary due to weekend/holiday calculations, CMS administrative extensions, disaster relief pauses, or the application of a specified state law. Always verify current timelines directly on the CMS NSA portal.