Important Updates to CMS IDR Portal Web Forms: What You Need to Know

The Centers for Medicare & Medicaid Services (CMS) has implemented several significant updates to the Federal IDR Portal's web forms on July 1, 2025. Since then, we have received a lot of questions about the changes, so we wanted to add some clarity about how the updates impact the dispute submission process.  

These changes affect how disputes are initiated, how health plan types are classified, and include new validation requirements. Here's what FHAS clients need to know about these updates. 

Key Changes to the Notice of IDR Initiation Web Form 

1) Updated Health Plan Type Classifications 

CMS has refined the terminology for health plan types to be more precise: 

• • "Fully insured private group health plan" is now "Fully insured ERISA group health plan" 
  • "Either partially or fully self-insured private (employment-based) group health plan" is now "Either partially or fully self-insured ERISA group health plan" 

2) New Requirements for Specific Plan Types 

Church Plans and Non-Federal Governmental Plans: If you're a health plan initiating a dispute and you select either a church plan or non-federal governmental health plan (such as state or local government plans), you must now specify whether the plan is “fully-insured” or “self-insured.” 

Self-Insured Health Plans: If you’re a self-insured health plan initiating a dispute, you must now indicate whether you have opted into any relevant specified state laws that apply to the items and services in dispute. This information is crucial for determining applicable regulations and payment standards. 

3) Enhanced Cooling Off Period Validations 

New Field - Dispute Reference Number: Initiating parties must now enter the dispute reference number when they indicate that the dispute was initiated following the completion of the 90-calendar-day cooling off period.

Automatic Verification: The system will then verify that there's a payment determination associated with that reference number issued at least 90 calendar days before your current submission date. 

4) New Date of Service Validations 

Timeline Validation: The system checks that all claim dates of service occur before the open negotiation start date (unless initiating parties indicate that they received an extension approval or the 90-day cooling off period applies)

Batched Disputes: The system now verifies that all items or services are within 30 business days of each other (unless the 90-day cooling off period applies) 

5) Duplicate Prevention Measures 

The CMS portal now prevents submission of duplicate dispute line items that share the same claim number, date of service, or service code as previously submitted dispute line items. 

Incorrect Duplicate Determinations 
Although this was meant to stop ineligible disputes from being submitted, some scenarios incorrectly prevented eligible disputes.  We've identified two such scenarios: 

1. 1. 1. Resubmissions after cooling off closures
      2. Two single disputes with identical claim information and CPT codes (where only a modifier would differentiate them, but the portal doesn't accommodate modifier input) 

If you encounter either scenario, email the federal IDR questions inbox explaining why your dispute isn't a duplicate and provide relevant supporting documentation for CMS to grant an extension. 

Updates to IDR Entity Selection Response Web Form 

1) Reorganized Layout 

The first page within the IDR Entity Selection Response web form has been reorganized to include the following: 

• • • The summary of qualified items and/or services table is directly after the “Notice of Initiation Form Documentation” section. 
    • New "Dispute Details" section follows the summary table. This section has information and questions about the health plan type.  
    • Contact information fields come after the Dispute Details section. 

2) Health Plan Type Attestation Requirements 

You must now attest to whether the health plan type selected by the initiating party is correct. If you disagree: 

• • • Select the correct health plan type from the available options 
    • The same naming updates mentioned above apply here 
    • Additional requirements for church plans, governmental plans, and self-insured plans mirror those in the initiation form 

If you select "Other," you must choose from specific categories where the No Surprises Act doesn't apply: 

• • • Medicare, Medicaid, Medicare Advantage 
    • TRICARE, Indian Health Services, Veterans Affairs 
    • Short-term Limited Duration, Excepted Benefits 
    • Retiree-only, Workers Compensation, Health Care Sharing Ministry 

Selecting "Other" automatically populates the Federal Applicability section to indicate the dispute isn't eligible for Federal IDR. 

Critical Limitation: Health plans can only attest to ONE health plan type per dispute, even in batched disputes that might involve multiple plan types. If this limitation occurs, contact the FHAS Account Services team with proof of the claim's health plan type for us to determine eligibility accurately. 

Changes to Notice of Offer Web Form 

Dynamic Content for Non-Responding Health Plans 

If a non-initiating health plan didn't complete the IDR Entity Selection Response form, the Notice of Offer form now includes dynamic content requiring: 

• • • Attestation about the health plan type accuracy 
    • Selection of correct health plan type if disagreeing 
    • Same additional requirements for specific plan types as outlined above 

Addressing Health Plan Type Discrepancies 

Common Client Question: "What happens if the health plan selects a different health plan type than what I originally selected?" 

FHAS Response Process: When health plan types differ between parties, FHAS will request additional information and proof to determine the accurate health plan type (if we don’t already have access to this information). We will: 

• • • Request supporting documentation from both parties 
    • Make changes only when sufficient evidence is provided 
    • Take appropriate action (continue or close the dispute) based on verified information 
    • Never favor one party's assertion without proper evidence 

Action Items for FHAS Clients 

• • Review your standard health plan type selections to ensure they align with the new terminology 
  • Prepare additional documentation for church plans, governmental plans, and self-insured plans 
  • Maintain detailed records of cooling off periods and reference numbers 
  • Double-check date ranges in batched disputes to ensure compliance with the 30-business-day rule (unless your dispute was affected by the cooling off period). 
  • Contact our team immediately if you encounter the two known duplicate blocking scenarios mentioned above 

Need Assistance? 

As always, the FHAS Account Team is here to help navigate these changes. If you have questions about how these updates affect your specific situations or need assistance with dispute submissions, please don't hesitate to contact our client services team at IDRE@fhas.com or 800-664-7177. 

For the complete text of CMS's official announcement, visit the CMS No Surprises Act Notices page.