Frequently Asked Questions
Process
C2C is made up of a diverse network of industry professionals with decades of experience and a clear understanding of IDR processes. The C2C team contains nurses, analysts, coders, auditors, paralegals and attorneys who all come together to use their in-depth understanding of health care revenue integrity and create a positive experience for IDR clients. C2C has been a successful entity in clinical quality improvement for nearly 30 years and, for much of this time, has been designated as a Quality Improvement Organization (QIO) providing over 1.5 million independent and impartial evaluations of health care access, quality and cost in the last decade alone. C2C is committed to guaranteeing the right care at the right time and at the right cost. For any questions regarding the No Surprises Act or for more information regarding any of its provisions, please refer to the Centers for Medicare & Medicaid Services (CMS) webpage about the No Surprises Act: https://www.cms.gov/nosurprises. Any inquiries related specifically to the federal IDR process or to initiate a dispute should be directed to the official CMS IDR email: FederalIDRQuestions@cms.hhs.gov.
The No Surprises Act protects patients from certain unexpected medical bills and establishes the IDR process to settle payment disputes between providers and payers. The No Surprises Act is a law that was passed in 2020 to protect patients from surprise billing, which is defined as unexpected medical bills for items or services from an out-of-network provider where the individual did not have the opportunity to choose from services covered by their health insurance or plan’s network (i.e., an in-network provider).
Either the provider or the health plan involved in a qualifying payment dispute may request IDR. For instance, IDR can be used by out-of-network medical providers, facilities, air ambulance providers and health insurance companies.
You can initiate a dispute with the IDR Initiation Form.
If any party has a concern regarding the review of a dispute, please use C2Cs’ communication portal to submit an inquiry: Independent Dispute Resolution Entity (IDRE) Inquiry Submission Portal. Inquiries are responded to on a first-come, first-served basis.
Timeline
The IDR process should be started within four business days after the close of the open negotiation period, unless the “cooling-off period” is applicable. Review CMS’ “Federal Independent Dispute Resolution (IDR) Process Guidance for Disputing Parties” to learn more about more about cooling-off periods.
When initiating a dispute in the CMS Portal, you will be asked to select an IDRE. Once the initiating party selects an IDRE and initiates the dispute, the non-initiating party will have the ability to agree or disagree with the selected IDRE. If the non-initiating party disagrees with the selected IDRE, then they will pick an alternative, which will have to be agreed upon by the initiating party. If both parties are not able to agree on an IDRE after three business days, then the IDRE for the dispute will be randomly selected from the remaining eligible options. If the non-initiating party does not respond to the IDRE selection response form, which is automatically sent by the CMS Portal when a dispute is initiated, then the initiating party’s selected IDRE will be assigned to the dispute. If you did not receive the “entity selection response email,” contact CMS for further instructions.
Documents
CMS provides specific guidance and resources for initiating parties on its “Helpful tips and tools for initiating an IDR dispute” webpage. This webpage includes links to common mistakes, communications, information about submitting a complete dispute initiation, information about submitting fees and information about getting help.
Based on CMS’ guidance, C2C recommends that the initiating party accurately complete the “Details” tab in the Federal IDR Portal, including the following:
The correct and complete contact information for the non-initiating party
The claim number of the items or services for which you are disputing payment
The qualifying payment amount for the items or services being disputed
A complete copy of remittance or notice of denial of payment from the health plan for the disputed item or service, along with the appropriate procedure codes
Documentation, such as copies of emails sent to the non-initiating party or a screenshot of a payee’s portal to demonstrate initiation of the required 30-business-day open negotiation period
An email from a certified IDRE requesting that a previously submitted dispute be resubmitted with corrections to batching errors, if applicable
An email that can serve as evidence of an extension being granted, if applicable
Batched Disputes and Bundled Disputes
Initiating parties can batch multiple items or services under the same dispute. Batching items and/or services helps to decrease the number of IDR proceedings, avoids unnecessary complications from single disputes from plans and providers and streamlines certified IDRE decision-making.
When multiple items or services from a provider (i.e., air ambulance or non-air ambulance) are billed or paid/denied under a single service code, such as a Diagnosis Related Group, it is considered a bundled arrangement for the purposes of the federal IDR process. Notice of IDR forms for bundled disputes must indicate the items or services were bundled. An entity cannot add Dispute Line Items that were not included in the original submission.
Bundled disputes contain multiple items and services that are represented by a single service code or single payment by one of the parties involved.
Batching allows an initiating party to submit multiple related items or services for a single IDR dispute that will be represented as a single patient encounter, identical service codes or a Current Procedural Terminology (CPT) Code Category I code section.
All of the following requirements must be met for items to be properly batched:
All items and services were from the same provider, group of providers, facilities or provider of air ambulance services under the same National Provider Identifier or tax identification number
Payment for the items and services must come from the same group health plan or insurance
The items that are included in the batch need to have occurred during a 30-business-day period following the date on which the earliest included item or service occurred or during a 30-business-day open negotiation period that ended during the same 90-calendar-day cooling-off period
The qualified IDR items or services must be related to the treatment of a similar condition
Note: Items or services that are related to the treatment of a similar condition can be found in the Federal Register: Vol. 88, No. 212 in “Table 2: Proposed Radiology CPT Code Spans for Permissible Batched Determinations-Level I HCPCS Codes (CPT)” (page 44), “Table 2: Proposed Radiology CPT Code Spans for Permissible Batched Determinations-Level I HCPCS Codes (CPT)” (page 45) and “Table 4: Proposed Anesthesiology CPT Code Spans for Permissible Batched Determinations” (page 46).
To be batched, the CPT codes need to be in the same grouping. For example, items and services for the following CPT codes could be batched because they fall under the same Diagnostic Radiology (Imaging) Grouping: 70010-71555, 72020-72295, 73000-73725, 74018-74363, 74400-74775, 75557-75989, 76000-76499, R0070-R0076.
Air ambulance services for a single air ambulance transport, including an air ambulance mileage code and base rate code, may be submitted as a batched dispute.
Cooling-Off Periods
The cooling-off period is the 90-calendar-day period following a payment determination when the initiating party cannot submit another Notice of IDR Initiation for the same or similar item or service involving the same non-initiating party from the previous payment determination.
A cooling-off period is applicable when the three criteria below are met:
The same parties are involved
A payment determination was made on the previous dispute
The new dispute involves the same or similar items or services as the previous payment determination
A subsequent submission is permitted for the same or similar items or services if the end of the open negotiation period occurs during the 90-calendar-day cooling-off period. For these items or services, either party must submit the Notice of IDR Initiation within 30 business days following the end of the cooling-off period, as opposed to the standard four-business-day period following the end of the open negotiation period. The 30-business-day period begins on the day after the last day of the cooling-off period.
Note: If the end of open negotiation is before the date of the previous rendered payment determination, a cooling-off period will not be applicable for the new Notice of IDR Initiation.
Payment
The administrative fee and the certified IDRE fee must be paid to C2C Innovative Solutions, Inc. Invoices are emailed to both initiating and non-initiating parties with payment instructions.
C2C Innovative Solutions, Inc.
Independent Dispute Resolution
301 W Bay Street
11th floor
Jacksonville, FL 32202
C2C Innovative Solutions, Inc.
Independent Dispute Resolution
P.O. Box 45310
Jacksonville, FL 32232-5310
Send the request to IDRInquiry@c2cinc.com to set up your account.
C2C
To be added with portal link and instructions
W9
You can access a copy of C2C’s W9 at