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VerdictCONSULTING GROUP

How do provider groups track unpaid IDR awards?

Verdict Consulting Group Research · Updated

Answer

By logging each federal IDR determination, setting a payment due date 30 calendar days later, and matching remittances against it. Awards still unpaid or short-paid after that date go on an aging report by payer and plan. Unpaid awards can be reported to the No Surprises Help Desk; whether a provider can sue depends on the court.

Detail

The tracking record

FieldWhy it matters
Determination dateStarts the 30-calendar-day payment clock under 45 CFR 149.510(c)(5)(ix)
Amount owedSelected offer, less the initial payment and patient cost sharing
Due date30 calendar days after the determination
Payments receivedAmount and date of each remittance matched to the award
StatusPaid, short-paid, late or unpaid, aged by payer and plan

What happens to awards that stay unpaid

CMS directs parties to the No Surprises Help Desk to report potential violations. Court routes are divided: the Fifth and Second Circuits hold there is no private right of action to enforce IDR awards. See What happens if a health plan does not pay an IDR award?.

Verdict Consulting Group offers IDR award payment tracking for provider groups and their counsel.

Sources

  1. Electronic Code of Federal Regulations — 45 CFR 149.510 — Independent dispute resolution process ()
  2. Centers for Medicare & Medicaid Services — About Independent Dispute Resolution ()
  3. Verdict Consulting Group — IDR award payment tracking for provider groups and counsel ()

General information only, not legal advice. Verdict Consulting Group is not a law firm.