Answers / The federal IDR timeline

The federal IDR timeline: every deadline in order

Nothing about No Surprises Act arbitration is intellectually hard. What kills claims is that every step has a countdown, the clocks are counted in different units, each payer remittance starts its own, and a group billing a few hundred out-of-network claims a month is running hundreds of overlapping timers. Here is the full sequence for one claim.

1. Day zero: initial payment or denial. The payer's payment or notice of denial starts everything. Not the date of service, not the date you billed. Every downstream clock keys off this remittance date, which is why clean remittance data matters more to IDR than any legal argument.
2. 30 business days to initiate open negotiation. You send the standard open negotiation notice to the payer. Miss this window and the claim's path to federal IDR is gone. This is where most recoverable revenue dies, quietly, with no notice from anyone.
3. 30 business days of open negotiation. The parties can settle at any point. Many disputes resolve here, and a settled claim never shows up in arbitration statistics. If nothing happens, the window simply expires.
4. 4 business days to initiate IDR. After negotiation ends, either party has 4 business days to file through the federal portal. Four days is short by design, and it is the second most common place claims are lost, especially over holidays and quarter-ends.
5. IDR entity selection, then 10 business days to submit offers. The parties select or are assigned a certified IDR entity, both sides deposit the arbiter's fee, and each submits a single offer with supporting evidence within 10 business days. This is baseball-style arbitration: the arbiter must pick one offer or the other, not split the difference.
6. Decision within 30 business days of selection. That is the regulatory target. In the real data, the median decided dispute from 2023 through 2025 took 37 days, and backlogged stretches ran longer.
7. Payment within 30 calendar days. The owing party must pay the determined amount within 30 calendar days of the decision. Note the unit change: calendar, not business. What happens when payment does not arrive is its own topic, covered in you won, now what.
8. 90 calendar days of cooling-off. After a determination, the initiating party waits 90 calendar days before bringing a new dispute against the same payer for the same or similar items and services. Claims whose windows would expire inside the cooling-off period are preserved: they can be filed within 30 business days after it ends. Untracked, this rule strands whole months of claims. Tracked, it just shapes the batch calendar.

Why this is a software problem

One claim, eight clocks, two units of time. Now multiply by every out-of-network remittance your group receives and overlay the batching windows, which have to align across up to 25 lines today and 50 from November 1, 2026. A paralegal with a spreadsheet can track dozens of these. Nobody tracks thousands by hand, which is why the audits we run keep finding the same thing: groups lose more to expired windows than to lost arbitrations. Providers win 85.8 percent of disputes that get decided. The claims that never get filed have a win rate of zero.