Earlier this year, the Departments of Health and Human Services, Labor, and the Treasury (collectively, the Departments), together with the Office of Personnel Management, released a final rule governing “Federal Independent Dispute Resolution Operations” (Final Rule). The Final Rule aims to streamline Federal Independent Dispute Resolution (IDR) operations. Key provisions address remittance information, open negotiation, batching, eligibility review, and future IDR Gateway functionality; however, the timing of the applicability of several provisions depend on system updates or additional guidance. As noted in the Final Rule, the Departments intend to issue future guidance when certain provisions apply. On August 7, 2026, the Departments published guidance clarifying the applicability dates and the implementation for each finalized provision. This document summarizes recent announcements and provides a timeline of each provision and applicability date.
- CARCs and RARCs: Under the Final Rule, plans and issuers must use standardized claim adjustment reason codes (CARCs) and specified remittance advice remark codes (RARCs) to communicate whether certain claims are subject to the No Surprises Act protections and Federal IDR. On July 17, 2026, the Departments released guidance that specifies the RARCs to be used for purposes of the Final Rule, the circumstances in which each RARC is to be used, and technical instructions to facilitate their use. Under the guidance, plans and issuers may continue to use the CARC they deem most appropriate for any claim adjustment. The requirement to provide CARCs and RARCs in the manner, circumstances, and timeframe specified in this guidance applies for items and services furnished on or after January 1, 2027.
- Batching: On August 3, the Departments published a notice that the functionality to support the treatment of batched qualified IDR items and services under the Final Rule will be available on November 1, 2026. As outlined in the Final Rule, for disputes with open negotiation periods beginning on or after November 1, 2026, batched disputes are limited to 50-line items. In addition, a payment determination also triggers a 30-business-day cooling-off period for certain subsequent disputes involving the same parties and item or service. The applicability date for the treatment of batched qualified IDR items and services is 90 calendar days after guidance published by the Departments. Therefore, all batching provisions in the Final Rule will be applicable for disputes with open negotiation periods beginning on or after November 1, 2026.
The Departments announced that in late 2026, the Federal IDR process will transition from single-use web forms to the secure, centralized IDR Gateway. In the IDR Gateway, users will be able to:
- Start and respond to disputes.
- Access dispute dashboards and reports associated with their organization.
- Track dispute information, including disputes assigned to a certified IDR entity.
- Monitor assigned disputes by process phase.
- Review notifications regarding dispute activity.
The Departments also announced that the IDR Gateway will add identity verification and restrict access to U.S.-based users.
Relatedly, on July 22, 2026, the Departments released updated IDR Public Use Files (PUF) covering 2025 Q3 and Q4. For the first time, each dispute line item in the PUF identifies the certified IDR entity that issued the payment determination, enabling comparisons across IDR entities, time periods, specialties, geographies, and service categories.
We continue to monitor developments related to the No Surprises Act and Federal IDR process. For more information on the No Surprises Act and Federal IDR, see our prior publications:
