Since the inception of IDR under the No Surprises Act, only a fraction of the disputes have been...
Resubmission Offers One Chance to Correct Batching Errors
The evolving rules and confusion that surrounds some aspects of IDR can not only delay claims, but in some cases, end them without a resolution. While errors during initial submission of eligible claims can often be corrected, the initiating party may only have one additional chance to get it right.
When it comes to mistakes in batching, IDR participants will only have a single opportunity to resubmit the claim correctly, and limited time to do so. If the deadline is missed, the error is repeated, or a new one is made, the claim is likely to be closed permanently, without additional recourse. Be sure you know how to avoid this outcome by becoming more familiar with resubmission.
Understand the New Resubmission Process
There have been a number of adjustments and clarifications since the launch of the No Surprises Act. One of the most recent involves the resubmission process. Since May of 2024, parties have a new way to resubmit disputes that were originally improperly batched.
Previously, resubmissions were accepted via the Notice of IDR Initiation web form. Starting in May of 2024, parties began using the “Notice of IDR Initiation – Resubmission” web form for all resubmissions.
In addition, any notice that resubmission is necessary will come directly from the Federal IDR portal instead of from your certified IDR entity. However, it is triggered by the entity handling the claim.
| All Resubmission Notification Emails come from: auto-reply-federalidrquestions@cms.hhs.gov |
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| Initiating Party receives a resubmission Link |
Non-Initiating Party receives an informational email only |
10-Business Days to Get it Right
As mentioned, when IDR items or services are batched incorrectly, the initiating party will only have one opportunity to resubmit each particular dispute line item.
The resubmission of any improperly batched items and services for reconsideration must occur within 10 business days of being notified by the certified IDR entity of the issue.
If the items and services are not resubmitted by the 10-business-day deadline, or if they are resubmitted and are again determined to be still improperly batched, the resubmitted dispute will be closed and ineligible for future resubmission.
We encourage initiating parties to review the current FHAS batching guidelines and to educate themselves on the difference between batching and bundling, and to minimize confusion about the processes.
| Batching | Bundling |
| Batching allows an initiating party to submit multiple related items or services for a single IDR dispute represented as a single patient encounter, identical service codes, or a Category I CPT code section. | Bundled disputes contain multiple items and services, but are represented by a single service code or single payment by one of the parties involved. |
IDR Entities Can Add Clarity
The May 2024 changes to resubmission also placed added emphasis on clearer explanations from Certified IDR entities that reject a batched submission. Since Initiating Parties only have one chance to resubmit, it’s critical that they know the specific reason that resubmission is necessary so that the mistake can be addressed properly.
An IDR entity may send all of dispute line items eligible for resubmission back to the initiating party for resubmission in one group, or they may send eligible disputes items or services back to the initiating party in multiple groups.
If the certified IDR entity sends the problematic cases back in multiple groups, the initiating party will receive multiple emails informing them that they need to be resubmitted. Each email will contain a unique link to a “Notice of IDR Initiation – Resubmission” web form.
It’s important to note that the initiating party should not assume that all dispute line items sent in a single grouping should be resubmitted together. It is the initiating party’s responsibility to ensure that all items submitted together in a single “Notice of IDR Initiation – Resubmission” web form are compliant with Federal IDR requirements for batching and that any resubmission addresses the underlying reason for rejection.
Get Answers from FHAS
Don’t put your claim at risk by resubmitting without a full understanding of the problem and the process. FHAS offers a highly-trained team of professionals and experienced arbitrators to ensure every IDR claim is handled efficiently and fairly from submission to determination.
If you have questions about your case with FHAS, or IDR resubmission generally, contact our service team for immediate help. You can also sign up for our IDR Insider Newsletter to regularly receive the latest analysis and resources from FHAS in your inbox. Visit FHAS.com, call 800-664-7177 or email us at IDRE@fhas.com to learn more.