No Surprises Act IDR Administrative Fee Drops to $15
A Final Rule Cuts the Per-Dispute Fee by More Than 85%, Effective for Disputes Initiated June 11, 2026
Summary of the Rule Change
HHS, the Department of Labor, the Treasury Department and OPM jointly finalized a rule on May 28, 2026 that overhauls parts of the No Surprises Act's federal Independent Dispute Resolution (IDR) process. The headline change is the administrative fee: it drops from $115 to a flat $15 per party, per dispute. The Departments say a flat rate for all disputes addresses concerns raised about equal access to the IDR process, which had become a real barrier for smaller practices disputing lower-dollar claims where the old $115 fee could exceed the amount actually in dispute.
The new fee applies to disputes initiated on or after June 11, 2026. IDR entity fees, the amount charged by the certified arbiter actually deciding the dispute, weren't changed by this rule; only the administrative fee paid to initiate the process dropped.
What Else Changed: CARC/RARC Codes and Batching
The rule also requires payors to use specific claim adjustment reason codes (CARCs) and remittance advice remark codes (RARCs) on initial payment or denial decisions for out-of-network claims, giving providers clearer, more standardized information about IDR eligibility directly on the remittance. Notably, the Departments extended this requirement to all claims, not just the ones subject to No Surprises Act protections, reasoning that providers need a clear signal for when a claim isn't subject to the Act's protections just as much as when it is.
This CARC/RARC requirement doesn't take effect immediately. The applicability date will be set by later sub-regulatory guidance, expected within roughly six months of the rule's publication, with the requirement itself taking effect about four months after that guidance, putting real-world compliance roughly 10 months out from publication. Separately, changes to the IDR registry, open negotiation period and dispute-initiation and batching rules take effect 90 days (or 90 business days, depending on the specific provision) after the Departments formally announce that the supporting technical functionality is available, which hadn't happened as of this writing.
- Track the June 11, 2026 fee-change date on any open or upcoming IDR disputes. A dispute initiated before that date is still subject to the prior fee structure.
- Watch for the forthcoming CARC/RARC applicability-date guidance. It applies to all claims, not only OON ones, so it affects remittance-reading workflows broadly.
- Don't assume the new IDR registry or batching rules are live yet. Those changes wait on a separate functionality announcement from the Departments.
Our No Surprises Act billing guide covers the underlying coverage and QPA rules this fee change sits inside, and our earlier update on CMS meeting IDR entities over dispute backlog covers the volume and operational pressure that led to this rule.
Verifiable References
- Sidley Austin LLP. US Government Finalizes No Surprises Act Independent Dispute Resolution Operations Rule. sidley.com/en/insights/newsupdates/2026/06
- Holland & Hart LLP. Revamp of the No Surprises Act Federal Independent Dispute Resolution Process. hollandhart.com/revamp-of-the-no-surprises-act-federal-independent-dispute-resolution-process
- Jones Day. New Rule Amends No Surprises Act Dispute Process for Out-of-Network Health Care Payments. jonesday.com/en/insights/2026/06
Related Resources
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