The No Surprises Act has been in effect for several years, but 2026 brings new rules to improve how providers and payers resolve certain out-of-network payment disputes.

On May 28, 2026, the Departments of Health and Human Services, Labor, and the Treasury, along with the Office of Personnel Management, released the Federal Independent Dispute Resolution (IDR) Operations Final Rule. The rule introduces several changes to the No Surprises Act (NSA) IDR process, with provisions taking effect throughout 2026-2027. Understanding these changes and reviewing your workflows will help your practice adapt smoothly.

Here’s a breakdown of the key No Surprises Act updates for 2026 and what they mean for providers and RCM teams.

What's Changing Under the No Surprises Act in 2026?

The 2026 changes focus heavily on the Federal IDR process. The goal is to reduce confusion, improve information sharing, make eligibility reviews more predictable, and help the system handle disputes more efficiently.

Let's explore key updates to the Federal IDR Operations Final Rule.

Better Information Sharing Between Payers and Providers

The Federal IDR process was established to help providers and payers resolve payment disputes when they cannot agree on an out-of-network rate. However, gaps in information exchange have made it harder for providers and payers to resolve these disputes.

The new rule aims to make that exchange more consistent. Payers must use Claim Adjustment Reason Codes (CARCs) and Remittance Advice Remark Codes (RARCs) to indicate whether a claim falls under the No Surprises Act’s surprise billing protections and whether it may be eligible for the Federal IDR process.

Payers must also include the following information with the initial payment or denial notice:

1. The legal name of the plan, insurance issuer, or Federal Employees Health Benefits (FEHB) carrier
2. The legal name of the plan sponsor, if applicable
3. The plan’s IDR Registry number
4. Instructions for providers to notify the Departments to begin open negotiation

Changes to IDR Administrative Fees

One of the most notable 2026 changes to the Federal IDR process is an 87% reduction in the administrative fee. For disputes initiated on or after June 11, 2026, the fee is $15 per party per dispute, down from $115.

The reduced fee applies regardless of the amount in dispute, lowering upfront costs for providers and payers and making the IDR process more accessible.

A Streamlined Open Negotiation Process

Open negotiation allows payers and providers to resolve a payment dispute before it moves to the Federal IDR process. The goal is to help both parties agree on a payment rate without incurring the additional time and costs associated with IDR.

However, parties have faced challenges with timely information exchange and effective engagement in the open negotiation process. To make the process more structured and easier to navigate, the 2026 rule introduces the following changes:

• The party initiating open negotiation must submit the open negotiation notice, along with the relevant payment remittance or notice of denial, via the Federal IDR portal.
• The open negotiation period is 30 business days from the date of submission of the required notice and supporting information.
• The open negotiation notice includes additional information to help identify the item or service involved and determine its eligibility for the Federal IDR process.

These changes clarify when open negotiation begins and what information must be exchanged before a dispute moves forward.

Clearer Rules for Batching Disputes

Batching allows providers and payers to combine multiple eligible items or services into a single IDR dispute, reducing the cost of disputing individual payments. However, limited flexibility in the batching rules makes it difficult for parties to group disputes efficiently.

The new rules clarify batching requirements for qualified IDR items and services. Under the 2026 provisions, parties may group:

• Services provided to the same patient on the same or consecutive dates of service and billed on the same claim.
• Services provided to one or more patients that use the same service code or a comparable code across different coding systems, such as CPT and HCPCS.
• Anesthesiology, radiology, pathology, and laboratory services that fall within the same Category I CPT section.

The 2026 rule also introduces a new batching limit. A single batched dispute can include no more than 50 qualified IDR line items. For practices handling a high volume of out-of-network disputes, this means RCM teams will need to be more deliberate in how they group claims and ensure each batch meets the applicable criteria.

A Simpler IDR Eligibility Process

Delays in determining IDR eligibility have long impeded timely payment determinations. The new rule establishes clearer review timelines:

• 5-day determination window: Certified IDR entities must determine whether a dispute is eligible within five business days of their final selection and notify the disputing parties and the Departments.
• 5-day response period: If additional information is needed to make the determination, the parties have five business days to submit the requested documentation; otherwise, the IDR entity will proceed with the available information or close the dispute.

Better Access to IDR Entity Information

Identifying the right payer has been a challenge in the Federal IDR process. Providers often struggle to find the correct payer and obtain their contact information, especially when the same plan sponsor offers multiple health plans. Certified IDR entities also struggle to distinguish among payers and track cooling-off periods.

The new IDR Registry addresses these gaps. Payers subject to the Federal IDR process must register with the Departments and provide information about their plans or coverage. Each registered plan or issuer receives a unique IDR registration number that includes the plan type, coverage, applicable state-law opt-in status, and contact information. This helps disputing parties identify the appropriate payer and determine whether a dispute is eligible for the Federal IDR process.

When Do the 2026 No Surprises Act Changes Take Effect?

Not all Federal IDR process updates take effect at the same time. Some changes are already in effect, while others take effect later in the year or in 2027. Here’s a quick timeline for providers and RCM teams:

• $15 IDR administrative fee: June 11, 2026
• Final rule effective date: August 3, 2026
• IDR Gateway account creation: September 15, 2026
• New batching rules and 50-line-item limit: November 1, 2026
• CARC/RARC disclosure requirements: January 1, 2027
• IDR Registry provisions: 90 business days after CMS announces that the supporting functionality is available

How RCM Teams Can Prepare for the 2026 Changes

The 2026 changes require RCM teams to rethink how they manage IDR-related claims and disputes. With a few targeted workflow updates, they can better manage the new IDR requirements.

• Update Your IDR Workflow: Align your IDR workflow with the new requirements. Submit open negotiation notices and required payment or denial information through the Federal IDR Portal. Assign clear ownership for identifying eligible disputes and gathering the documentation needed to support each case.
• Strengthen CARC/RARC Tracking: Train your billing team and update remittance workflows to identify the required CARCs and RARCs on electronic remittances. Use these codes to determine whether a claim may fall under No Surprises Act protections and requires further IDR review. Where applicable, capture related payer information, including the QPA, and route potential disputes for timely follow-up.
• Reconfigure Claim Batching Engines: Review your batching process to ensure claims meet the new IDR criteria. Keep each batch within the 50-line-item limit and group claims according to applicable requirements, such as patient encounters, matching service codes, or qualifying specialty categories.
• Confirm Payer Identification Through the IDR Registry: Use the IDR Registry to verify payer and plan information before starting an open negotiation.
• Build a Reliable IDR Timeline Process: Track every important IDR deadline, from open negotiation through IDR filing and eligibility review. Assign clear ownership for each step and set up automated reminders or calendar alerts so your team receives timely notifications and doesn't miss critical deadlines.

Stay in Step With Regulatory Changes

The 2026 No Surprises Act updates change how providers manage out-of-network payment disputes. Managing these requirements manually adds another layer of work for already busy billing teams.

Glenwood Systems helps alleviate that burden with an integrated EHR-RCM platform that streamlines key revenue cycle activities. GlaceRCM promptly incorporates regulatory updates, ensuring practices stay aligned with changing requirements.

As No Surprises Act requirements continue to evolve, the right processes and technology help you stay compliant, simplify administrative workflows, and support ongoing compliance.