--- title: "Final IDR Rule: Key Takeaways" description: Federal agencies issued a final rule to streamline the No Surprises Act IDR process without changing patient protections or payment methodology. image: https://blog.nisbenefits.com/hubfs/blog-headers/idr-b.jpg --- ![Dispute resolution mind map](https://blog.nisbenefits.com/hubfs/blog-headers/idr-b.jpg) # Final IDR Rule: Key Takeaways - Home - [Employee Benefit News for School, City and County Employers](https://blog.nisbenefits.com) - Final IDR Rule: Key Takeaways [ Valerie Ortiz ](https://blog.nisbenefits.com/author/valerie-ortiz) 06/17/2026 [ Early Retiree Benefits](https://blog.nisbenefits.com/topic/retiree-benefits), [ Legislative News](https://blog.nisbenefits.com/topic/aca-other-legislative-news) [0 Comments ](https://blog.nisbenefits.com/final-idr-rule#postComment) 2 Minutes On June 4, 2026, the Departments of Labor, Health and Human Services, and the Treasury issued a [final rule](https://www.federalregister.gov/documents/2026/06/04/2026-11140/federal-independent-dispute-resolution-operations) to improve the federal independent dispute resolution (IDR) process under the [No Surprises Act](https://www.cms.gov/nosurprises) (NSA). Key operational updates, including a new IDR registry, will roll out as new functionality becomes available. While TPAs or issuers typically manage IDR disputes without employer involvement, employers should still monitor IDR activity as part of their fiduciary oversight and review any TPA or issuer reports. Employers with self-insured plans should also ensure their TPA completes the required IDR registration once the registry is live.   ## **Background** The NSA protects patients from unexpected medical bills by limiting out-of-network cost sharing and banning balance billing for most emergency care, certain nonemergency services at in-network facilities, and out-of-network air ambulance services. It also created a federal IDR process to settle payment disputes between health plans and out-of-network providers when state rules do not apply. Since launching in April 2022, this IDR process has received over 5 million disputes, leading to significant backlogs and higher administrative costs.   ## **Final Rule** The final rule is designed to streamline the IDR process by reducing delays and inefficiencies. It does not change the No Surprises Act’s patient protections or the formula for out-of-network payments. Key updates include: - **Administrative fee:** The final rule cuts the nonrefundable IDR administrative fee from $115 to $15 per party, per dispute, for cases initiated on or after June 11, 2026; - **Payer registration: **The final rule creates a new federal IDR registry for self-insured health plans and health insurance issuers, assigning each an IDR registration number. This is intended to simplify eligibility checks, clarify coverage type, and improve information sharing in disputes. Payers must register within 90 days of the registry opening; - **Open negotiation through federal portal:** The NSA created a 30-business-day open negotiation window so payers and providers can try to agree on a payment amount before using IDR. Because many parties were skipping this step, the final rule strengthens open negotiation requirements and will move the process into the federal IDR portal once that functionality is available; - **Batching rules:** The NSA allows parties to “batch” multiple items or services into a single IDR dispute to control costs. The final rule expands this by doubling the cap from 25 to 50 items per dispute and letting providers batch by single-patient encounters and certain code ranges. These changes apply to disputes with open negotiation periods starting on or after November 1, 2026; and - **Disclosure and remittance code requirements:** The final rule also standardizes how payers communicate with out-of-network providers by requiring specific claim adjustment reason codes and remittance advice remark codes on all paper and electronic remittance notices. Additional implementation guidance is expected from the Departments. Download the [bulletin](https://blog.nisbenefits.com/hubfs/blog-supporting-docs/bulletin-final-rule-idr-process.pdf) for more details. 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