Implement the No Surprises Act open negotiation and federal Independent Dispute Resolution (IDR) workflow for a disputed out-of-network claim

Steps

1. After an out-of-network claim is adjudicated, confirm that the service qualifies as a covered IDR item (generally emergency services, certain non-emergency services at in-network facilities, and air ambulance services from non-network providers).
2. Initiate a 30-business-day open negotiation period by sending the payer a written notice specifying the claim, the amount requested, and supporting rationale; document the negotiation attempt thoroughly.
3. If open negotiation fails within 30 business days, initiate a federal IDR dispute through the CMS IDR portal within 4 business days after the end of the open negotiation period.
4. Select a certified IDR entity from the approved list or allow the parties to jointly select one; if no joint selection is made within the required window, CMS assigns an entity.
5. Submit your offer amount and supporting documentation to the certified IDR entity, including any relevant information about the qualifying payment amount (QPA) and why your offer is appropriate.
6. The IDR entity selects one of the two parties' offers (baseball-style arbitration); implement the selected payment within the required timeframe and update your AR accordingly.