As a leading Independent Dispute Resolution Entity (IDRE) under the No Surprises Act, iMPROve Health delivers fair, efficient, and fully compliant arbitration services for payment disputes between out-of-network providers and health plans. Drawing on more than 40 years of clinical and regulatory review expertise, we ensure impartial, evidence-based determinations that align with federal requirements and promote timely resolution. Our experienced team combines deep healthcare knowledge with a commitment to accuracy, transparency, and operational excellence, providing stakeholders with confidence in every decision rendered.
iMPROve Health provides:
▪ IDR Case Initiation & Management
▪ Expert Arbitrator Assignment
▪ Comprehensive Evidence Evaluation
▪ Regulatory Compliance Oversight
▪ Custom Reporting
To choose iMPROve Health (IDREApp-151) as your certified IDRE, see the list of entities.
About the No Surprises Act
The No Surprises Act (NSA), enacted as part of the Consolidated Appropriations Act of 2021, protects patients from unexpected medical bills and certain forms of surprise billing. Effective January 1, 2022, patients are safeguarded from surprise charges in the following situations:
▪ Emergency services
▪ Certain non-emergency services provided by out-of-network clinicians at in-network facilities
▪ Air ambulance services furnished by out-of-network providers
Under these protections:
▪ Excessive out-of-pocket expenses are limited
▪ Emergency services must be covered without the need for prior authorization
▪ Consumers may not be balance billed for out-of-network services in covered circumstances
Prior to the NSA, patients could be responsible for the difference between a provider’s billed charges and the amount paid by their health plan, a practice known as balance billing, even when care was received at an in-network facility. The No Surprises Act significantly restricts this practice, providing stronger financial protection for patients.
Learn more here: Overview of Rules & Fact Sheets
When to Initiate a Federal IDR Dispute
A Federal Independent Dispute Resolution (IDR) dispute may be initiated only after the required 30-business-day open negotiation period has concluded.
▪ A Federal IDR dispute must be initiated within four (4) business days following the end of the open negotiation period, unless an extension is granted by the Departments.
▪ To initiate a dispute, please submit the required information through the CMS Federal IDR portal: IDR Notice of Initiation Form (use the Notice of Independent Dispute Resolution (IDR) Initiation Form User Guide).
Federal IDR Process Timeline · Click to Collapse / Expand
Federal Independent Dispute Resolution
Process Timeline
A step-by-step guide for providers and payors navigating payment disputes under the No Surprises Act
Standard Timeline Steps
Timeliness Objection Points
Cooling-Off Period
Post Cooling-Off / Restart
The provider receives the initial payment amount or notice of denial from the payor.
This event starts the Federal IDR process clock.
Either party may initiate an open negotiation period after receiving the initial payment or denial.
Up to 30 business days to file
Parties must exhaust a full 30-business-day open negotiation period before proceeding to formal IDR.
30 business days
Parties may continue to negotiate throughout the entire process, up until a final payment determination is made.
After the open negotiation period ends, either party may formally initiate the Federal IDR process.
Up to 4 business days after ON ends
If the window is missed, a valid reason must be provided to proceed.
Parties have 3 business days from initiation to mutually agree on a certified IDR Entity (IDRE).
If no agreement is reached, the Departments assign one within 6 business days.
3 BD agreed · 6 BD if Dept. assigned
The certified Entity attests it has no conflict of interest (COI) and determines whether the Federal IDR process applies to this specific dispute.
3 business days
Both parties submit their respective payment offers and pay the required administrative fees to the certified IDR Entity.
10 business days
The certified IDR Entity reviews all submissions and selects one party's offer as the binding final payment determination.
30 business days after IDR selection
Any outstanding amount owed must be remitted from one party to the other following the final determination.
No later than 30 calendar days
No new IDR initiations are allowed for the same or similar item or service between the same parties during this period.
90 calendar days
Once the cooling-off period expires, either party may initiate new disputes for services rendered during the 90-day window.
30 business days to initiate
Need Help Navigating the Federal IDR Process?
iMPROve HEALTH is a federally certified Independent Dispute Resolution Entity (IDRE) — here to guide you every step of the way.
For iMPROve Health general IDRE questions, please email FederalIDRE@improve.health.
For IDR payment/refund questions, please email IDREAccounting@improve.health.
