The Departments of Health and Human Services (HHS), Treasury, and Labor (Departments) released the Independent Dispute Resolution (IDR) Operations final rule under the No Surprises Act (NSA). The NSA instituted protections against out-of-network balance billing and created the IDR process to resolve payment disputes for certain out-of-network services between providers and payers. Initially proposed in November 2023, this final rule makes long-awaited changes that the Departments believe will improve the efficiency and transparency of the IDR process. This resource reviews important changes for medical groups participating in the IDR process.

The official publication date of the final rule in the federal register is June 4, 2026, and its general effective date is August 3, 2026 (60 days following its publication).1 Many of the provisions in the final rule are dependent on the Departments releasing additional guidance. For the finalized changes related to open negotiations, batching requirements, IDR process eligibility review, and additional policies, the Departments will release guidance on a rolling basis and anticipate all functionality will be available by August 2028 (24 months after the final rule’s effective date). Medical groups should begin planning for these operational changes to the IDR process and continue monitoring for additional information.

Further, the Departments believe the final rule lays the foundation for the new IDR Gateway they are planning to introduce in the latter half of 2026. The IDR Gateway will centralize disputes, allow users to start and respond to them, access dispute dashboards to track dispute information, monitor assigned disputes, and review notifications regarding dispute activity.