How to File an
IDR Dispute

What You’ll Need to File a Dispute

Before filing a Federal IDR dispute, make sure you have all the required information ready. Having these details on hand will help ensure a smooth submission process and avoid unnecessary delays. The list below outlines what you’ll need to gather in advance.

  • Information to identify the qualified IDR items or services, including:
    • Dates and locations that the items or services were provided
    • Types of items or services such as emergency services and post-stabilization services
    • Codes for corresponding service and place-of-service
    • A complete Explanation of Benefits (EOB)
    • Claim numbers involved in the dispute
  • Attestation that items or services are within the scope of the Federal IDR process
  • Complete and correct contact information for the non-initiating party
  • The preferred certified IDR entity from the list of certified organizations 

Notice of
IDR Initiation

The Notice of IDR Initiation form is required by the initiating party to be sent to the non-initiating party and must be completed and submitted through the Federal IDR Portal.  Notice of IDR Initiation may be sent electronically to the non-initiating party (for example via email).

  • The initiating party must have a good faith belief that the electronic method is readily accessible by the other party
  • The Departments issued a standard notice of IDR initiation
  • The Notice of IDR Initiation sent to the Departments must be submitted through the Federal IDR portal.

Extensions and Extenuating Circumstances

Certain time periods in the Federal IDR Process may be extended in the case of extenuating circumstances at the Departments’ discretion.

  • Time periods for payments cannot be extended
  • What qualifies as “extenuating circumstances” for an extension: The Departments may extend time periods if the extension is necessary to address delays due to matters beyond the control of the parties or for good cause. Such an extension may be necessary if, for example, a natural disaster impedes efforts by the disputing parties to comply with time-period requirements.
  • How to request an extension: Extensions are provided on a case by case basis, parties may request an extension, and provide applicable attestations, by emailing a Request for Extension Due to Extenuating Circumstances to federalidrquestions@cms.hhs.gov, including an explanation about the extenuating circumstances that require an extension and why the extension is needed.