Beginning November 1, 2026 federal IDR will be applicable only to those disputes for which the open negotiation period begins on or after this date. Disputes submitted during this time frame are subject to an additional 50-line-item limit per dispute, as well as a 30 business day "cooling off" period prior to submitting a batched payment determination. Additionally, the IDR Portal will include functionality to prevent the filing of claims both before the allowed time period and after the allowed time period. Additionally, the final rule includes an additional regulation unique to radiology services – allowing radiology services to file under category I cpt codes as CMS has outlined in their supplemental guidance.
The IDR Gateway will operate independently of other clocks and will have its own deadline of January 15, 2027. Please note that the $15 Administrative Fee was implemented on June 11, 2026, and therefore is NOT included in these changes.
Quick Answer
- These new rules apply to "batched" dispute resolution cases which begin their negotiation period on or after November 1st, 2026.
- Batched payments are limited to 50 individual items per case.
- Payment Determination of a Batched Payment Case is subject to a 30-Business-Day Cooling Off Period. The filing of the Dispute Resolution Document must be done after that time has elapsed but no later than four (4) Business Days thereafter.
- Single, Bundled, and prior Batched Disputes remain under the existing 90 Calendar Day Cooling Off Period.
Federal IDR November 1 2026: What Applies and When
Your initial open negotiation start date and your selected dispute type determine what regulations are applicable. That is not when you submitted the claim.
| Change | Applies to | CMS source |
|---|---|---|
| 50 line item cap | Batched disputes, open negotiation start on or after Nov. 1, 2026 | Notices, Aug. 3 and Oct. 2, 2026 |
| 30-business-day cooling-off period | Same group | Notices, Aug. 3 and Oct. 2, 2026 |
| Filing window of 4 business days after cooling-off ends | Same group | Notice, Oct. 2, 2026 |
| Web forms end, except the resubmission form | All parties, after Jan. 15, 2027 | Notice, Sept. 15, 2026 |
How Batching Works for Radiology
CMS counts line items (qualified services) not claims
The final rule provides that batching is allowed under three circumstances: 1) all of a single patient's encounters; 2) services billed with the same service code; and 3) anesthesia, radiology, pathology and laboratory services billed using codes from the same Category i cpt section.
Do all radiology services automatically batch? No. In order to be eligible for batching, the service codes involved must be contained within the same Category i cpt section as determined by CMS. As stated in CMS' guidance, the "50 line item cap" also applies.
Will CMS identify those sections? Yes. CMS has indicated that it will identify those sections via future notice page postings. Therefore, prior to creating any batches, your radiology coders and medical billing services personnel should meet to discuss how they plan to group the services into code categories. It would also be beneficial to label each created batch based upon the rule(s) being used (i.e., encounter, shared service code, Category i cpt section), such that if the batch were reviewed, the reviewer could follow the logic.
The 30-Business-Day Cooling-Off Period
Once you've made a determination of liability (payment) on a batched dispute, the party filing the dispute cannot file another dispute with the same other party about the same product or service for at least thirty (30) business days. The 30 business day limitation is applicable to parties whose open negotiation start date is on or after November 1.
Both Single Dispute Resolution and Bundled Dispute Resolution do not have a shortened window. Both continue to allow 90 calendar days before the Respondent can be challenged again in an additional dispute.
Enter the Determination Date as soon as you receive notification. In any event, these payments are already being followed up upon via your medical accounts receivable services, therefore one tracking system will save redundant work.
The 4-Business-Day Filing Window
Here is the catch. The portal validations will end any dispute that was filed prior to the end of the cooling off period or within four (four) business days after the end of the cooling off period. Use a calendar based tool to calculate business days instead of manually counting them.
Will the portal block a late-filed dispute? Yes. According to CMS, the validation stops the submission from being made.
The blocked submissions for late filings leave underpaid claims for out-of-network providers stuck in limbo; and subsequently are passed along as denied claims into your denial management services queues.
Why Older, Single, Batched and Bundled Disputes Follow Different Rules
The Radiology Group is able to have all four dispute types active at the same time as CMS links each rule to the dispute type and the date when negotiations begin.
| Dispute type | Cooling-off period | Filing window after it ends | 50 line item cap |
|---|---|---|---|
| Batched, open negotiation starts on or after Nov. 1 | 30 business days | 4 business days | Applies |
| Batched, open negotiation starts before Nov. 1 | 90 calendar days | 30 business days | Not covered |
| Single | 90 calendar days | 30 business days | Not applicable |
| Bundled | 90 calendar days | 30 business days | Not applicable |
The Federal IDR November 1 2026 line splits your caseload in two, so sort every open case into one row before you file anything.
Gateway Transition and the January 15, 2027 Deadline
The IDM Gateway became available to create accounts beginning with September 15, 2026. The web forms will remain open for submission without creating an account until January 15, 2027. However, after this date, all submissions from web forms will be excluded from being submitted via the Gateway, unless you are using the "Notice of IDR Initiation-Resubmission" web form. November 1 is NOT the Gateway’s deadline. Make sure to plan separately for each of these deadlines.
If a party uses a third-party administrator, they do not have to obtain an account; however, the administrator MUST register. Additionally, the IDM Gateway will verify identities and only allow access for U.S.-based users. Compare this policy to the policies your firm has in place for your filing staff.
What Should Radiology Practices Test Before November 1?
CMS sets the rules. The tests below are our recommendations.
Ten Workflow Tests
- Pull all open case start dates for active negotiations.
- Tag all cases either as a "single," "bundled" or "batched" case.
- Split any "batched" case into two batches based on their start date; prior to November 1 (the date CMS changed its billing rules) and after.
- Determine how many lines are in each batch; if it is greater than 50, then split that batch into smaller groups.
- Match the Radiology codes with the Category I CPT section Rule in CMS's Guidance document.
- Check the Modifiers: The Duplicate Check, done by CMS, includes Claim Number, Date of Service, Service Code, and Modifier(s).
- Record the Payment Determination Date for each Batched Case.
- Calendar the Cooling-Off End Date plus four business days.
- Identify which individuals hold Gateway Accounts, including administrators.
- Walk one Mock Batch through your entire process from beginning to end.
What to Monitor After November 1
CMS has issued a number of notices, so make sure to look at the CMS notices page every week or two and watch for some additional guidance on naming the radiology section, the Gateway cutover, and how you will be required to act with respect to follow-up from the Fifth Circuit's ruling in its August 11, 2026 TMA III decision on whether certain payments qualify as payment. In addition to the date on which other final rule provisions (i.e., the open negotiation notice, and the Payer IDR Registry) become effective, are dependent upon CMS making an announcement about those dates.
15-Item Checklist
- Timeline of open negotiations recorded by case
- Type of dispute is coded
- All pre- November 1 batches are flagged to be processed in accordance with the 90 day rule.
- Each batch has a cap of 50 line items.
- All radiology codes have been cross-referenced to ensure they match CPT Section Guidance
- Duplicate line items will no longer be accepted
- All determination dates will now be entered into the system
- The last day of the cooling off period will be calendared
- The filing deadline will be calendared
- A Gateway Administrator has been designated (CMS recommends designating at least one).
- The Third Party Administrator has been verified
- The user account status for all gateway users has been verified as being based within the United States.
- Nevertheless, staff have still been trained on how to do the cool down math.
- Weekly review of the Notices Page is required.
Frequently Asked Questions
CMS has determined that a single, batched dispute may be limited to no more than 50 line items once CMS's open negotiation period begins (on or after) November 1, 2026.
No. All web forms will cease being available through the gateway on January 15, 2027 with one exception - the resubmission form.
No. Both single and bundled disputes remain under the 90 calendar day cooling off period.
No. The $15 fee per party was implemented as of June 11, 2026 in regards to disputes submitted on or after that date.
As of January 1, 2025, when you submit another batch of radiology disputes, there will be a 50 line item limit per submission and the number of lines that may be submitted will be dependent upon the date range (start date) of each of your open cases. At Human Medical Billing we can assist you with reviewing all of your open cases for disputes, sorting those cases by dispute type and start date, and identifying which batch is likely to reach or exceed the 50 line item cap. We can also help you determine how many batches you should plan to submit based on the federal IDR guidelines effective November 1, 2026.
Please contact us to schedule a workflow review prior to submitting your next batch of disputes.
Contact Human Medical Billing to schedule a compliance readiness review or learn more about our end-to-end billing and regulatory support services.
