Eligibility in the Federal IDR Process: A shared responsibility – and a shared opportunity for improvement
Eligibility in the Federal IDR Process: A Shared Responsibility
Four years into the No Surprises Act, the Federal Independent Dispute Resolution (IDR) process continues to evolve and improve, and eligibility remains an important area for improvement.
The good news is that ineligibility rates have steadily declined, from approximately 69% in early 2022 to 16% in the most recent CMS data from January–May 2026. Recent news repeating that 40% of disputes filed are ineligible conflate ineligible assertions with ineligible findings.
NAIROs latest paper explores why eligibility determinations can be complex and how providers, payers, and independent dispute resolution entities (IDREs) each have a role to play in making the process more efficient.
Clearer information. More complete filings. Better communication. Consistent application of the rules.
When every participant does their part, fewer disputes are found ineligible, eligible cases can move more quickly, and the IDR process works better for everyone.