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.
September 15, 2026 Program Partial Launch IDR Gateway account registration opens ahead of the transition CMS opened IDR Gateway account creation while continuing to describe the dispute-management transition as planned for late 2026. Existing web forms generally remain available outside the Gateway through January 15, 2027; after that date, only the Notice of IDR Initiation - Resubmission form is excepted from the announced restriction.
CMS opened IDR Gateway account creation while continuing to describe the dispute-management transition as planned for late 2026. Existing web forms generally remain available outside the Gateway through January 15, 2027; after that date, only the Notice of IDR Initiation - Resubmission form is excepted from the announced restriction.
Primary record
01 Sign Up Now for the IDR Gateway! ↗September 11, 2026 Program Capacity Change · Dispute intake pending at review Departments certify a seventeenth IDR entity: medlitix The Departments certified Physio Solutions, LLC, doing business as medlitix, expanding the Federal IDR roster from 16 to 17 entities. Certification adds authorized capacity; it does not by itself establish that the entity has begun accepting disputes or improved processing times.
The Departments certified Physio Solutions, LLC, doing business as medlitix, expanding the Federal IDR roster from 16 to 17 entities. Certification adds authorized capacity; it does not by itself establish that the entity has begun accepting disputes or improved processing times.
Roster checked · September 18, 2026. CMS listed medlitix as not accepting new disputes at this review. Certification and active dispute intake are separate milestones.
September 3, 2026 Congressional Oversight Pallone requests arbitration records from six IDR entities House Energy and Commerce Ranking Member Frank Pallone sent oversight letters to six certified IDR entities requesting records on eligibility decisions, awards, staff compensation, automation, and financial relationships. Responses were requested by September 24, 2026; the inquiry did not itself establish violations or amend the No Surprises Act.
House Energy and Commerce Ranking Member Frank Pallone sent oversight letters to six certified IDR entities requesting records on eligibility decisions, awards, staff compensation, automation, and financial relationships. Responses were requested by September 24, 2026; the inquiry did not itself establish violations or amend the No Surprises Act.
August 11, 2026 Appellate Decision En banc Fifth Circuit rejects key TMA III QPA calculation rules The full Fifth Circuit rejected rules permitting ghost rates for services a provider does not furnish and excluding bonus and incentive payments from the qualifying payment amount (QPA). It upheld exclusion of single-case agreements, affirmed the district judgment in part, reversed it in part, and remanded for further proceedings.
The full Fifth Circuit rejected rules permitting ghost rates for services a provider does not furnish and excluding bonus and incentive payments from the qualifying payment amount (QPA). It upheld exclusion of single-case agreements, affirmed the district judgment in part, reversed it in part, and remanded for further proceedings.
August 3, 2026 Program Update Announced CMS sets November 1 applicability for IDR batching changes CMS announced that the final rule's batching provisions will apply to disputes with open negotiation periods beginning on or after November 1, 2026. Those batched disputes will be limited to 50 line items, and their payment determinations will trigger a 30-business-day cooling-off period for subsequent disputes involving the same parties and item or service.
CMS announced that the final rule's batching provisions will apply to disputes with open negotiation periods beginning on or after November 1, 2026. Those batched disputes will be limited to 50 line items, and their payment determinations will trigger a 30-business-day cooling-off period for subsequent disputes involving the same parties and item or service.
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 ↗May 30, 2025 Appellate Order Fifth Circuit grants TMA III rehearing en banc and vacates panel opinion The full court granted rehearing and automatically vacated the October 2024 panel opinion, restoring the district judgment as the operative judicial baseline pending en banc disposition.
The full court granted rehearing and automatically vacated the October 2024 panel opinion, restoring the district judgment as the operative judicial baseline pending en banc disposition.
October 30, 2024 Appellate Decision · Panel opinion later vacated 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.
Subsequent history · September 18, 2026. The Fifth Circuit vacated this panel opinion when it granted rehearing en banc on May 30, 2025. Its August 11, 2026 en banc decision rejected the challenged ghost-rate and bonus-payment QPA rules, upheld the exclusion of single-case agreements, and remanded the case. This entry preserves the earlier procedural stage.
Primary records
01 Opinion, Texas Medical Association v. HHS (TMA III) ↗ 02 Memorandum Opinion and Order, Texas Medical Association v. HHS (TMA III) ↗ 03 Order Granting Rehearing En Banc, Texas Medical Association v. HHS (TMA III) ↗ 04 Texas Medical Association v. HHS: en banc opinion, No. 23-40605 ↗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.