On 5/28/26, the Departments of Health and Human Services, Labor, and the Treasury released final rules modifying the Federal independent Dispute Resolution Operations. 

These new final rules:

• require the disclosure of information that group health plans and health insurance issuers offering group or individual health insurance coverage (referred to as “plans and issuers”) must include along with the initial payment or notice of denial of payment for certain items and services subject to the surprise billing protections in the No Surprises Act;
• require plans and issuers to communicate information by using claim adjustment reason codes (CARCs) and remittance advice remark codes (RARCs), as specified in guidance, when providing any paper or electronic remittance advice (ERA) to an entity that does not have a contractual relationship with the plan or issuer;
• amend certain requirements related to the open negotiation period, the initiation of the Federal IDR process, the Federal IDR dispute eligibility review process, and the payment and collection of administrative fees and certified IDR entity fees;
• define bundled payment arrangements;
• amend requirements related to batched items and services;
• amend the rules for extensions of timeframes due to extenuating circumstances; and

• require plans and issuers to register in the Federal IDR portal.

  Groom will be publishing a summary of the final rule. For additional questions about these or any other policies included in the final rule, please contact any of the authors or your Groom attorney.