Health Law Daily Wrap Up, HEALTH CARE REIMBURSEMENT NEWS—Federal rule targets IDR process inefficiencies with new disclosure and communication mandates, (Jun 1, 2026)

By Patricia K. Ruiz, J.D.

The final rule revises dispute resolution operations under the No Surprises Act to emphasize standardized data exchange and procedural clarity.

A new final rule issued by HHS, Departments of Labor, Treasury, and the Office of Personnel Management (Departments, collectively) revises key operational aspects of the federal independent dispute resolution (IDR) process established under the No Surprises Act. The advance release of the final rule, released with a fact sheet, finalizes requirements governing disclosures, communication protocols, and procedural timelines intended to improve the efficiency and transparency of payment disputes for outofnetwork items and services. It also codifies new definitions, modifies batching and bundling standards, and introduces obligations affecting plans, issuers, and providers across the IDR lifecycle. The final rule takes effect 60 days after publication in the Federal Register.

Standardized communication requirements. The rule requires plans and issuers to use claim adjustment reason codes (CARCs) and remittance advice remark codes (RARCs) when providing remittance advice—whether paper or electronic—to entities with which they lack a contractual relationship. These codes must be used, as specified in forthcoming guidance, to communicate whether items or services are subject to the No Surprises Act and to convey other claimadjudication information relevant to dispute eligibility.

According to the final rule, the Departments determined that standardized use of CARCs and RARCs will address communication gaps that have contributed to ineligible disputes and administrative inefficiencies. The requirement applies broadly to all remittance advice issued to outofnetwork entities, including items and services not subject to No Surprises Act protections, in order to clarify applicability and reduce inappropriate IDR submissions.

Implementation details, including specific code combinations and timing, will be provided through agency guidance. Plans and issuers are not required to comply until an applicability date is established in that guidance.

Expanded QPA disclosure obligations. The final rule amends disclosure requirements related to the qualifying payment amount (QPA), a central benchmark in the IDR process. Plans and issuers must provide QPA information not only when it determines cost sharing, but also when the billed amount is used as the basis for cost sharing. The Departments concluded that access to QPA information is necessary in all instances where an item or service may be eligible for IDR, regardless of the calculation method used.

Additional required disclosure elements include identifying information such as the legal business names of plans or issuers and, where applicable, plan sponsors, as well as registration numbers tied to a new federal IDR registry. These disclosures are intended to facilitate more efficient identification of parties and improve the initiation and conduct of negotiations.

Federal IDR registry, registration requirement. The rule requires plans and issuers to register with a federal IDR portal and obtain a registration number. That number must be included in required disclosures and used throughout the dispute process to identify the responsible entity. The registration requirement is designed to improve accuracy in dispute submissions and enable better tracking of eligibility, particularly in cases involving selfinsured plans or thirdparty administrators.

Failure to register within specified timeframes will constitute a violation of the rule.

Procedural changes to open negotiation. The rule imposes new requirements governing the 30businessday open negotiation period that precedes IDR initiation. Parties must submit open negotiation notices and responses through the federal IDR portal using standardized forms. The open negotiation period begins on the date the notice is submitted through the portal to both the opposing party and the Departments.

The rule also establishes a requirement that the receiving party provide an open negotiation response notice within 15 business days. Both notices must include detailed information about the item or service, the parties involved, payment amounts, and supporting documentation, including remittance advice.

While the rule enhances procedural structure, it does not impose penalties within the IDR process itself for failure to respond or negotiate in good faith. Instead, enforcement will rely on existing authorities under applicable statutes.

Clarification of bundled, batched disputes. The rule finalizes a definition of “bundled payment arrangement,” describing circumstances in which multiple services are billed or reimbursed under a single service code representing an episode of care. Such arrangements may be submitted as a single dispute, though not all batching rules apply. The Departments declined to limit bundling to specific coding systems or require mutual agreement between parties, instead adopting a broader definition to increase flexibility and accessibility of the IDR process.

Operational context, objectives. The rule responds to sustained operational challenges in the federal IDR system, including high dispute volume, delays in eligibility determinations, and inconsistent communication between parties. As of early 2026, more than 5.1 million disputes had been submitted since the system’s launch, far exceeding original projections. By standardizing data exchange, clarifying eligibility requirements, and centralizing communication within the IDR portal, the Departments aim to reduce ineligible filings and improve processing efficiency.

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