The system in motion
2022—2026
A statute becomes an operating system
Once the protections took effect, the central story moved from enactment to administration: a dispute portal, changing fees, court-ordered revisions, mounting volume, and an infrastructure still being tuned.
July 22, 2026 Agency Data Release Departments release second-half and full-year 2025 IDR data The release documented 2,559,375 initiations, 2,799,243 closures, and 2,227,286 payment determinations for 2025 and added certified-entity identity fields for Q3-Q4 records.
The release documented 2,559,375 initiations, 2,799,243 closures, and 2,227,286 payment determinations for 2025 and added certified-entity identity fields for Q3-Q4 records.
June 4, 2026 Rule Final Federal IDR operations final rule is published Publication created the controlling final text, including a general 60-day effective date, the earlier fee date, and later staged or system-dependent applicability rules.
Publication created the controlling final text, including a general 60-day effective date, the earlier fee date, and later staged or system-dependent applicability rules.
February 19, 2026 Government Research Report GAO reports selected network-participation and payment trends before and after applicability GAO analyzed selected provider specialties and services from 2019 through 2023, finding increased in-network shares for three of four specialties and payment patterns largely continuing preexisting trends.
GAO analyzed selected provider specialties and services from 2019 through 2023, finding increased in-network shares for three of four specialties and payment patterns largely continuing preexisting trends.
June 12, 2025 Program Capacity Change Departments expand certified IDR entity roster from 13 to 15 Capitol Bridge and Livanta/Commence were certified, expanding listed decision-making capacity.
Capitol Bridge and Livanta/Commence were certified, expanding listed decision-making capacity.
Primary record
01 Certification of Additional Federal IDR Entities ↗October 30, 2024 Appellate Decision Fifth Circuit issues mixed TMA III QPA-methodology decision The court reversed vacatur of challenged QPA-calculation provisions, affirmed vacatur of the clean-claim deadline provision, and affirmed the disclosure requirements.
The court reversed vacatur of challenged QPA-calculation provisions, affirmed vacatur of the clean-claim deadline provision, and affirmed the disclosure requirements.
February 15, 2024 Agency Data Release Departments publish first detailed 2023 federal IDR public-use data The first 2023 public-use release documented 288,810 initiations, 83,868 determinations, eligibility friction, concentration among initiating parties, and prevailing-offer patterns for January through June.
The first 2023 public-use release documented 288,810 initiations, 83,868 determinations, eligibility friction, concentration among initiating parties, and prevailing-offer patterns for January through June.
August 3, 2023 Court Decision TMA IV vacates $350 fee and same-code batching provisions The court held the agencies improperly bypassed notice and comment, vacated the $350 fee and three parallel batching provisions, and rejected refund and deadline-extension requests.
The court held the agencies improperly bypassed notice and comment, vacated the $350 fee and three parallel batching provisions, and rejected refund and deadline-extension requests.
April 27, 2023 Agency Report Departments report first-year federal IDR volume and backlog For April 15, 2022 through March 31, 2023, the Departments reported 334,828 initiations and described high volume, complex eligibility review, and ongoing technical and operational changes.
For April 15, 2022 through March 31, 2023, the Departments reported 334,828 initiations and described high volume, complex eligibility review, and ongoing technical and operational changes.
April 15, 2022 Program Launch Federal IDR portal opens The Departments opened the federal IDR portal for eligible payment disputes and allowed transitional initiation for disputes whose open-negotiation periods had expired before launch.
The Departments opened the federal IDR portal for eligible payment disputes and allowed transitional initiation for disputes whose open-negotiation periods had expired before launch.
February 23, 2022 Court Decision Eastern District of Texas vacates portions of Part II IDR rule TMA I held that the challenged QPA presumption conflicted with unambiguous statutory text, found no good cause for bypassing notice and comment, and vacated enumerated non-air-ambulance IDR provisions.
TMA I held that the challenged QPA presumption conflicted with unambiguous statutory text, found no good cause for bypassing notice and comment, and vacated enumerated non-air-ambulance IDR provisions.
January 1, 2022 Statutory And Regulatory Applicability Core No Surprises Act protections become applicable Federal patient protections, plan and issuer duties, provider and facility limits, good-faith estimates for uninsured or self-pay individuals, and related mechanisms generally became applicable, while the federal IDR portal remained unavailable.
Federal patient protections, plan and issuer duties, provider and facility limits, good-faith estimates for uninsured or self-pay individuals, and related mechanisms generally became applicable, while the federal IDR portal remained unavailable.