On September 21, 2023, the Departments allowed certified IDR entities to resume processing single and bundled disputes that were submitted by August 3, 2023, but effective today certain new single and bundled disputes can be initiated. While the Departments are updating guidance and operations to comply with recent court orders, the following disputes remain suspended: new and in progress batched disputes, and new air ambulance disputes. For those parties impacted by these temporary suspensions, additional time will be granted to submit and respond to new disputes as set out below in a recent CMS email:

• Parties for whom the Federal IDR initiation deadline required by regulation falls on a date beginning August 3, 2023, through November 3, 2023 will have until the 20^th business day after the Federal IDR portal reopens for new dispute processing, which is November 3, 2023, to initiate a new dispute.  
• For new disputes initiated between October 6, 2023, and November 3, 2023, the deadline for certified IDR entity selection will be 10 business days after initiation, and the deadline to submit fees and offers will remain 10 business days after certified IDR entity selection. 
• Disputing parties that were engaged in certified IDR entity selection when the Federal IDR portal temporarily closed will have 10 business days from October 6, 2023, to agree on a certified IDR entity.
• All other deadlines under the Federal IDR process remain unchanged.

Additional information can be found at these resources or by contacting the undersigned:

IDR Admin Fees FAQs (cms.gov)

No Surprises Act (NSA) Independent Dispute Resolution (IDR) Partial Reopening of Dispute Initiation Frequently Asked Questions (FAQs), October 6, 2023 (cms.gov)

FAQS ABOUT CONSOLIDATED APPROPRIATIONS ACT, 2021 IMPLEMENTATION PART 62 (cms.gov)

No Surprises Act | CMS