Batching IDR disputes

Every line in a batch must share the same two parties:

1. Same provider, group or facility. Bill under one tax ID or group NPI. Don’t mix groups.
2. Same plan or insurer. The same group health plan or the same issuer. A self-funded plan administered by an insurer is a different party from that insurer’s fully insured business. Check the plan, not the logo on the card.

Pick one of these for each batch. Every line in the batch has to fit the same rule.

1. One patient, one encounter.
Services to a single patient on one day or on consecutive days, billed on the same claim form. Example: a surgeon’s primary procedure and a second procedure on the same claim.

2. Same or comparable service code.
Services to one or more patients billed under the same code, or a comparable code in a different code system (CPT with modifiers, HCPCS, DRG). Example: twenty 99285 ED visits across twenty patients, all with the same insurer.

3. Anesthesia, radiology, pathology and lab: same CPT section.
For these four specialties, codes that sit in the same Category I CPT code section can share a batch even if the codes differ. The exact code ranges come from federal guidance. Check the current CMS guidance before relying on this one.

• Open negotiation. Each line needs its own 30-business-day open negotiation period before it can go in a batch. The batch’s open negotiation start date is what decides which rules apply.
• Filing window. You have 4 business days after open negotiation ends to start IDR.
• Service date window. Lines in a batch must fall within the same 30-business-day period of service. To confirm against the final rule text before mailing. This was the rule before November 1 and we believe it carries over.
• Cooling-off period. After a decision on a batched dispute, the party that filed must wait 30 business days before filing again against the same other party for the same item or service. The old rule was 90 calendar days.
• No duplicates. A line item that’s already in a pending dispute can’t go in another one.

Two separate fees. Both parties pay both up front.

Each certified entity publishes its own fee. The ranges above are what entities actually charge in 2026. See the CMS certified entity list for current numbers, or our arbiters page.

Why this changes the math. A single $400 line item isn’t worth a $425 to $800 entity fee on its own. Twenty of those lines with the same insurer, under one code, can share one batched fee.

• It doesn’t make an ineligible claim eligible. Every line still has to pass eligibility on its own (see our eligibility page). If the arbitrator finds one line ineligible, that line comes out; the rest can proceed.
• It doesn’t let you mix insurers, mix groups, or mix code rules in one batch.
• It doesn’t change the deadlines. Miss open negotiation on a line and that line can’t join.

1. Sort underpaid lines by insurer and plan.
2. Inside each insurer, sort by service code.
3. Count them. If a code has 2 to 50 lines with open negotiation ending in the same window, that’s one batch.
4. Anything left over with the same patient and claim form can batch as an encounter.
5. Anything still left over is a single dispute. Decide if it clears the fee.

We propose the batches. Your group approves which disputes get filed, and we agree roles with your billing team up front.