Tips for Disputing Parties

Some documents on this page include guidance pertaining to rules that have been vacated by Texas Medical Association, et al. v. United States Department of Health and Human Services, Case No. 6:23-cv-59-JDK or Texas Medical Association, et al. v. United States Department of Health and Human Services, Case No. 6:22-cv-450-JDK. These decisions vacated rules related to batching of IDR disputes, the administrative fee amount for IDR disputes, requirements related to the timeframe for sending an initial payment or notice of denial of payment, the methodology for calculating qualifying payment amounts (QPAs), and/or provisions pertaining to air ambulance disputes. Please review the opinions in the cases cited above for further information on which provisions of the regulations and guidance were vacated and the notes on our website about applicable guidance. Disregard those specific sections of these documents to the extent inconsistent with the court’s opinions.

Common mistakes and helpful tips for parties initiating an IDR dispute:

Before initiating a dispute, please review the following resources and read through the common mistakes and best practices outlined below in order to ensure that your dispute is processed as quickly and efficiently as possible.

Common Mistakes
To ensure your dispute is processed as quickly as possible, please avoid these common mistakes:

  • Incorrectly batching cases
  • Incorrectly submitting disputes involving bundled qualified IDR items or services.
  • Failing to use the contact information provided with the initial payment or notice of denial of payment
  • Failing to include the Qualifying Payment Amount (QPA) provided with the initial payment or notice of denial of payment.
  • Failing to provide documentation of initiation of open negotiation, if the non-initiating party reports that open negotiation did not occur.

Please consult Technical Assistance for Certified Independent Dispute Resolution Entities-August 2022 Edition (PDF) if you are missing information from a non-initiating party needed to submit a complete dispute initiation.


  • Check your spam folder for emails from If necessary, contact your IT department to add this email to your safe senders list to avoid spam blocking.
  • Provide the certified IDR entities, the Federal IDR system, and other parties to disputes with contact information for the individual who will be responsible for receiving and responding to communications, and update contact information when it changes.
  • Ensure that you have correct contact information for the other party to your dispute. If necessary, contact the other party to verify contact information before beginning the dispute. Using incorrect contact information can lead to delays in processing. If you have difficulties getting the information you need from the other party, file a billing complaint or contact the Departments of Health and Human Services (HHS), Labor and the Treasury (the Departments) at for assistance.

Submitting Fees

  • Once you’ve selected a certified IDR entity, be sure to check with the certified IDR entity on its requirements for submitting administrative fees and certified IDR entity fees.
  • Ensure that you have submitted the administrative fee and correct certified IDR entity fees to the certified IDR entity. If you do not pay your administrative and certified IDR entity fees, the certified IDR entity will not review the offer you submit in the dispute.

Submitting a Complete Dispute Initiation

  • Ensure that your dispute initiation is complete. The following items are frequently missing and will cause delays in processing:
    • The Qualifying Payment Amount (QPA) for the items or services being disputed
    • Correct and complete contact information for the non-initiating party
    • The claim number of the item or services for which you’re disputing payment
  • We encourage parties to upload the following items to the Federal IDR system during initiation to ensure disputes move through the process efficiently: 
    • Copy of remittance or notice of denial of payment for the disputed item or service
    • Documentation (such as copies of emails sent to the non-initiating party) to demonstrate initiation of the required 30-business-day open negotiation period.
    • Email from a certified IDR entity requesting a previously-submitted dispute be resubmitted with corrections to batching errors (if applicable).
    • An extension email which can serve as evidence of an extension being granted (if applicable).

Batching and Bundling Disputes

Getting Help

  • Send questions to the Federal IDR mailbox at
  • You may also contact the No Surprises Help Desk at 1-800-985-3059 from 8 a.m. to 8 p.m. ET, 7 days a week, to ask questions or to report any potential violations of the process.
  • If you would like to take part in the Federal IDR process by sending an Open Negotiation Notice or IDR Initiation form to a group health plan, health insurance issuer, Federal Employees Health Benefits (FEHB) carrier, or a provider, facility, or provider of air ambulance services and you are missing contact information, QPA information, or any other required information, contact the party directly to request the information. If you have difficulty obtaining the information from the other party, you may file a complaint from the NSA website. You may also apply for an extenuating circumstance extension for review by the Departments. If approved, you will not miss the timelines required by the Federal IDR process.
Page Last Modified:
10/06/2023 08:44 AM