Remittance advice
Paid against a low benchmark
Insurers pay what they choose, measured against the qualifying payment amount: a benchmark a federal appeals court found artificially low.
UnderpaidYou treated the patient.
We recover what it was worth.
Federal and state IDR, handled from claim to payment.
Millions
recovered for clients
Many clients recover
75–90%
of billed charges
Varies with your chargemaster
~$100M
under management
The problem
Out-of-network care is underpaid by default.
The No Surprises Act gave providers a way to dispute low payments. It also gave them strict rules, tight clocks and an insurer on the other side arguing every claim.
Final offers
One number wins
In IDR each side submits a single offer and the arbitrator picks one. Nothing in between. The better-supported case wins.
SelectedNotice of IDR initiation
The clock never stops
30 business days from payment to open negotiation, 30 more to negotiate, then 4 to file. Miss a window and the claim can be forfeited.
ForfeitedEligibility objection
Every claim is contested
Insurers routinely argue that claims don’t qualify. Industry-wide, about one dispute in five is dismissed.
DismissedSources: Texas Medical Ass’n v. HHS (5th Cir.); CMS Federal IDR public use files, 2025.
Illustrative
+$756.80
A loss can still pay. When the payer’s $3,500 offer is selected, you still net $756.80 above the $2,000 initially paid, after fees.
Count dollars, not wins.
See The Strategy →Most providers contest only a fraction of eligible claims, because the process is too slow and too manual to do at scale. The rest is revenue left on the table.
How it works
From intake to final payment, handled.
IDR Advocate connects to the systems you already use and runs every step of federal and state IDR.
- 01
Intake & batching
We pull qualifying claims from your EHR and batch them under the federal batching rules, so even small disputes are worth filing.
- 02
Open negotiation
We open negotiation on every eligible claim, send the notices and track every negotiation window, federal or state.
- 03
The brief
Each case is built from your own records and cited to the literature, then sharpened with our QPA models and caselaw.
- 04
Filing & objections
We file in the right forum inside every deadline, manage IDR entity selection and answer objections with the facts and the law.
- 05
A decision isn’t money. We collect it.
We follow every determination to payment, match remittances and chase variances until the account closes. How payment works →
- 06
Analytics
Recovery, payer behavior and outcomes in one place, so each new filing learns from the last.
Command center
Every dispute, every deadline, one view.
See your whole IDR portfolio by stage, payer and service line. Deadlines count down on their own, high-value cases rise to the top and nothing waits on a spreadsheet.
- Real-time status from intake to payment
- Automatic deadline monitoring and alerts
- Claims prioritized by recovery value and likelihood of success
The brief
The best-supported case in the room.
We build each brief from your own records: patient acuity, complexity of care and your clinicians’ training, all cited to the literature. Proprietary QPA machine-learning models and analysis of caselaw, from Guardian Flight to TMA III, do the rest.
- Every statutory factor under 45 CFR 149.510 addressed
- Initial submissions, rebuttals and settlement letters
- Optional expert review for high-value or complex cases
QPA counters
Every QPA, countered.
Plans anchor on the QPA, and many pay less than it. We rebuild the payment from the remittance, line by line, and file a counter that shows the IDR entity exactly where the plan’s number falls apart.
- Checks whether the plan paid its own QPA
- Rebuilds the payment from every remittance code
- Flags cuts with no stated legal basis
- Asks the plan to produce the inputs behind its QPA
- Ties each argument to the statutory factors and current case law
Finance & analytics
Your finance team sees every dollar.
Accounting is told when a claim enters IDR, what to expect and when. Collections pause during active disputes, payments are matched to determinations and every variance gets followed up.
- A/R aging by dispute stage and recovery projections
- Payer and IDR-entity behavior from your offer history
- Complete audit trail from intake to account closure
Connects to data from Epic · Cerner · Athena · FinThrive · Federal & state IDR portals · Slack & Teams
Some systems are white-glove: we build those integrations as part of our agreement with your health system. Product names are trademarks of their owners.
Learn
Our strategy, and the rules of IDR.
The scoreboard
Wins are the wrong scoreboard.
Federally, providers are selected in 80–90% of disputes. A high count is easy if you ask for less. We ask for full value.
What most advocates report
80–90%
of federal disputes won
Easy to reach if you ask for less.
What we measure
75–90%
of billed charges recovered
For many of our clients. Results vary with your chargemaster. The examples below use separate assumptions and deduct example fees.
One dispute
A loss can still pay.
Each side submits one final offer, and the arbitrator picks the one closer to its view of value. To win, the payer has to raise its offer toward that value.
Final-offer arbitration
Illustrative
Net lossNet gain
- Payer’s offer, selected
- $3,500.00
- IDR entity fee (loser pays)
- −$450.00
- Transaction fee
- −$293.20
- Net to you
- $2,756.80
Versus the $2,000 Initially Paid
+$756.80
Net gainLose at $3,500 and still net $756.80 above the $2,000 initially paid. Illustrative: the losing side pays the IDR entity fee ($450 here); the transaction fee is $293.20 per case.
100 disputes
Lose most of them. Still come out ahead.
Ask for 100% of billed charges on every claim. When the payer defaults, you’re paid in full. When it contests, it has to raise its offer to win.
100 claims, each Initially Paid $2,000
Illustrative
Payer defaults (18): paid $6,000You win (20): paid $6,000Payer wins (62): paid $3,500
- Initially Paid, 100 claims
- $200,000.00
- Paid in full (38 × $6,000)
- $228,000.00
- Payer wins (62 × $3,500)
- $217,000.00
- Fees
- −$57,220.00
- Net to you
- $387,780.00
Versus the $200,000 Initially Paid
+94%
Cases won: 38 of 100.
Net gainIllustrative. Your offer is 100% of billed charges ($6,000); a payer that wins offers $3,500. The loser pays the $450 IDR entity fee, including a payer that defaults; the transaction fee is $293.20 per case. In 2025, payers defaulted in about 18% of federal disputes (CMS Federal IDR public use files).
Pricing the offer
Why we ask for 100% of billed charges.
Ask for less and you win more cases. Ask for full charges and you collect more money.
The same 100 claims
Illustrative
Your offer
100%
of billed charges · $6,000
Cases won
38
of 100
Net vs. Initially Paid
+94%
$387,780 net
See the numbers
| Your offer | Cases won | Net to you | Vs. Initially Paid |
|---|
Illustrative model on the same 100 claims: initially paid $2,000, billed charges $6,000, benchmark $4,000, 18% payer defaults, fees as above. The arbitrator’s view of value varies around the benchmark. The payer’s offer is held at $3,500; in practice payers offer less when you ask for less, so lower asks would do worse than shown.
The record
The law weighs what insurers ignore.
Arbitrators must weigh these factors. We document every one. We never miss a filing.
- Patient acuity
- Complexity of care
- Clinician training
- Teaching status and case mix
- Market share
- Good-faith contracting
42 U.S.C. § 300gg-111(c)(5)(C)
Federal and state
Federal is steady. State is where results vary.
Federal
Providers win most disputes. The question is how much you collect.
State
Each state sets its own benchmark, batching and fees.
Example: Georgia
Arbitrators see the FAIR Health median, and each request covers up to four patients.
See Georgia law →Examples are illustrative. Federal figures: CMS Federal IDR public use files, 2025. Recovery varies with your chargemaster, payers and states.
The process
Seven steps, from claim to payment.
The federal process, step by step, with the details that decide real disputes.
-
01 · Eligibility and forum
Is the claim eligible, and where does it go?
Federal IDR covers emergency care, care by out-of-network clinicians at in-network facilities, and air ambulance, for plans the No Surprises Act covers. Medicare, Medicaid, CHIP and TRICARE are outside it. Where a state law reaches the plan, the provider and the service together, the state process applies instead.
The nuance
- “Fully insured” does not automatically mean state. A plan regulated by another state can fall outside the care state’s law and go federal. 42 U.S.C. § 300gg-111(a)(3)(I); 45 C.F.R. § 149.30
- Self-funded employer plans go federal unless the plan opted into a state that allows it, and opt-ins must be renewed. Check the plan documents, not the carrier name on the card. 29 U.S.C. § 1144; e.g., O.C.G.A. § 33-20F-2
- Network status follows the product. A contract for an insurer’s employer plans does not cover its Marketplace plans unless it says so. 45 C.F.R. § 149.30
- Emergency status turns on the patient’s symptoms on arrival, not the final diagnosis. 26 U.S.C. § 9816(a)(3)
-
02 · Open negotiation
Negotiate for 30 business days.
Open negotiation must start within 30 business days of the plan’s initial payment or denial, by sending the standard notice. If the two sides do not agree within 30 business days, either can start IDR.
The nuance
- The clock only runs once the notice is properly delivered. A notice that never reached the other side may mean the 30 days never began. CMS, Federal IDR Guidance for Disputing Parties
- The other side does not have to respond. Silence does not pause the clock. 45 C.F.R. § 149.510(b)(1)
-
03 · Filing and batching
File within 4 business days. Batch where you can.
After negotiation ends, either side has 4 business days to start IDR. Similar claims can be combined into one dispute to share fees.
The nuance
- A batch needs the same provider, the same plan, a similar condition and service within 30 days. Since a 2023 court ruling, each IDR entity decides what counts as “similar.” 42 U.S.C. § 300gg-111(c)(3)(A); CMS FAQs Part 63 (2023)
- For disputes whose negotiation starts on or after November 1, 2026, a batch is capped at 50 line items and must share one encounter, a comparable service code, or, for anesthesia, radiology, pathology and lab, the same code section. 91 Fed. Reg. 33900 (2026)
- Batching and bundling differ. A bundled payment under one code is one line item; a batch groups separate items, each decided on its own. 91 Fed. Reg. 33900 (2026)
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04 · Offers and evidence
Submit one final offer, with the evidence.
Each side submits a single number and the evidence behind it. The IDR entity weighs the factors below, and no factor, including the QPA, is presumed correct.
The nuance
- Good-faith contracting looks at both sides’ network efforts and contracted rates over the past four plan years, not at conduct in one negotiation. 42 U.S.C. § 300gg-111(c)(5)(C)
- A plan’s silence in negotiation is likely not enough on its own, but it can support a broader pattern of refusing to contract. 42 U.S.C. § 300gg-111(c)(5)(C)
- Federally, billed charges are off limits as evidence. Some states require their arbitrators to weigh them: Georgia’s must consider the usual and customary cost of physician services. 45 C.F.R. § 149.510(c)(4); Ga. Comp. R. & Regs. 120-2-106-.10
-
05 · Decision
The arbitrator picks one offer.
The IDR entity must decide within 30 business days of being selected, and it picks one offer, nothing in between. The losing side pays the entity’s fee.
The nuance
- Closed disputes can now be corrected for clerical, jurisdictional or procedural errors. A reissued decision restarts the payment clock. CMS, Errors Identified After Dispute Closure (June 2025)
- State decisions can be final in a way federal ones are not: a Georgia arbitrator’s decision cannot be appealed in court. O.C.G.A. § 33-20E-15
-
06 · Cooling off
Wait before refiling the same service.
After a decision, the side that started the dispute must wait 90 calendar days before filing again for the same or similar service against the same plan.
The nuance
- Only the side that started the dispute is barred, and each decision starts its own waiting period. 45 C.F.R. § 149.510; 91 Fed. Reg. 33900 (2026)
- Claims whose negotiation ended during the wait get 30 business days, not calendar days, to file once it ends. 42 U.S.C. § 300gg-111(c)(5)(E)
- For batched disputes whose negotiation starts on or after November 1, 2026, the wait drops to 30 business days and covers only the same service code. 45 C.F.R. § 149.510(h)(5); 91 Fed. Reg. 33900 (2026)
-
07 · Getting paid
Collect within 30 days.
The plan must pay a federal award within 30 calendar days of the decision. In Georgia, the losing side pays within 15 days and the winner is paid within 3 days after that.
The nuance
- Nothing collects automatically, and no interest runs on a late federal award until a court enters judgment. 42 U.S.C. § 300gg-111(c)(6); 28 U.S.C. § 1961
- Courts are split on enforcing awards. The Fifth Circuit found no private right to sue; some courts elsewhere have confirmed awards as judgments. The question is unsettled. Guardian Flight (5th Cir. 2025), cert. denied (2026); 9 U.S.C. § 9
- Complaints to CMS or the state regulator build a record, but penalties go to the government, not to the provider. 45 C.F.R. § 149.510
- For self-funded plans, the plan, not the administrator processing claims, owes the award. Complaints go to CMS and the Department of Labor. 29 C.F.R. § 2590.716-8
Summary for general information, not legal advice. Federal rules as of October 2026.
The factors
What the arbitrator weighs.
Each side submits one final offer. The arbitrator picks the one that best represents the value of the care, weighing the benchmark and these factors.
The benchmark
Qualifying payment amount (QPA)
The plan’s median contracted rate for the same service in the area. The arbitrator must consider it, and a federal appeals court found it artificially low.
Evidence that helps: The plan’s QPA disclosures, and proof of where it is miscalculated.
Factor 1
Patient acuity and complexity of care
How sick the patient was, and how hard the care was to deliver.
Evidence that helps: Diagnoses, severity, procedures performed, and the time and resources used.
Factor 2
Training, experience, quality and outcomes
The skill of the clinicians and the results they deliver.
Evidence that helps: Board certification, specialty training, experience, and quality and outcome measures.
Factor 3
Market share
The share of the local market held by the provider or by the plan.
Evidence that helps: Local market data for the service line and the plan’s enrollment in the region.
Factor 4
Teaching status, case mix and scope of services
For facilities: what the hospital is and what it is equipped to do.
Evidence that helps: Teaching affiliation, case-mix index, trauma designation and service lines.
Factor 5
Good-faith contracting
Each side’s efforts to agree on a network contract, and any contracted rates in the past four years.
Evidence that helps: Contract offers, negotiation history and prior contracted rates.
Not allowed: billed charges, usual and customary charges, and Medicare, Medicaid, CHIP or TRICARE rates. Your offer can be any amount; the evidence must come from the factors above.
Federal IDR: 42 U.S.C. § 300gg-111(c)(5)(C)–(D); 45 C.F.R. § 149.510(c)(4). States weigh their own lists; see each state below.
Every state
Which process applies where.
Federal IDR covers every state. Some states add their own process for the plans they regulate. Click a state to see its rules.
State process + federalState law; hospital claims go federalFederal IDR only
Click a state to see which process applies.
Onboarding
Live in 30 to 60 days. We do the heavy lifting.
White-glove implementation with minimal disruption to the way your team works today. If your internal reviews take longer, we work at your pace.
-
Phase 1
Discovery & security
We review your EHR, revenue-cycle and contract systems, map your claims data and sign the BAA and NDA before any data moves.
-
Phase 2
Connect & configure
We connect by API, SFTP, HL7/FHIR or on-premises, load six months of history as a baseline and set QPA thresholds, timelines and user roles.
-
Phase 3
Review & train
Your leadership sees the platform running on your own data, with ROI projections. Users are trained in a few short sessions.
-
Phase 4
Go live
We run test claims end to end, then launch with daily check-ins through the first week and real-time issue resolution.
What we need from you
- A claims data feed, including 835 and 837 files
- Six months of out-of-network claims history
- Payer contract information
- One integration contact on your team
- A 2–3 hour discovery session
After launch
- Support that answers when you call
- Monthly performance reviews
- Quarterly business reviews with full ROI analysis
- Continuous tuning of workflows and models
Security & compliance
- We sign a BAA before any patient data moves
- HIPAA-compliant data handling
- Encrypted in transit
- Role-based, logged access
- On-premises deployment available
Built for
- Health systemsDirect EHR integration, multi-facility reporting, high-volume batching
- Community hospitalsRight-sized implementation on cost-effective cloud deployment
- Medical groupsSimple cloud connections with a focus on high-dollar claims
- Surgery centersAnesthesia billing and facility/professional split handling
ROI
What are your unfiled claims worth?
Most of the value is in the claims you aren’t disputing today. Adjust the numbers to match your organization.
FAQ
Questions hospital leaders ask us.
What is IDR?
Independent dispute resolution is the No Surprises Act’s process for settling out-of-network payment disputes between providers and health plans. Open negotiation must start within 30 business days of the plan’s initial payment or denial. After 30 business days of negotiation, either side can initiate IDR within 4 business days. Each side then submits one offer, and a certified IDR entity picks one. Many states also run their own process for the plans they regulate; we file in whichever forum applies.
Which claims qualify?
Emergency care, care by out-of-network clinicians at in-network facilities, and air ambulance, under plans the No Surprises Act covers. Medicare, Medicaid, CHIP and TRICARE are excluded, and some states run their own process. We screen every claim for eligibility and the right forum, federal or state, before it’s filed.
Do we have to change systems?
No. We connect to the EHR and billing systems you already use, including Epic, Cerner, Athena and FinThrive, by API, SFTP, HL7/FHIR or an on-premises server. Some systems are white-glove: we build those integrations as part of our agreement with your health system.
How much of our team’s time does it take?
A 2–3 hour discovery session, a few short training sessions per user, brief daily check-ins during launch week and a weekly optimization call after that. Deadlines, filings and follow-up are ours.
Is a person involved, or is it all automated?
Both. The platform handles intake, deadlines, briefs and reconciliation. For high-value or complex cases, expert reviewers can check the brief before it’s submitted.
How do we get started?
Prove it on your own claims in 90 days. Start with one state or one payer, see the results, then expand.