No Surprises Act IDR Batching Changes: What Radiology Groups Must Do

What Changes for No Surprises Act IDR Batching on November 1, 2026?

As of October 2026, the No Surprises Act IDR batching change refers to new federal rules that let radiology groups batch up to 50 out-of-network line items in one dispute when the services fall in the same Category I CPT section. The rules apply to disputes whose open negotiation period begins on or after November 1, 2026.

• Who it affects: Radiology groups that read out-of-network studies at in-network facilities and use federal independent dispute resolution to contest low payments.
• What it changes: Bigger, broader batches, a $15 administrative fee per party, and new remittance codes for services furnished starting January 1, 2027.
• What to do now: Sort open claims by when open negotiation began, rebuild batching logic around line items, and confirm who on your team files disputes.

What the Final IDR Rules Change

The Departments of Health and Human Services, Labor, and the Treasury, with the Office of Personnel Management, published the Federal Independent Dispute Resolution Operations final rules in the Federal Register on June 4, 2026 (Document 2026-11140). The rules took effect August 3, 2026, but many provisions apply on later dates. CMS’s IDR Operations Implementation Timeline guide, dated August 7, 2026, confirms that all batching provisions apply to disputes with open negotiation periods starting on or after November 1, 2026.

The batching change matters most for radiology because the rules name anesthesiology, radiology, pathology, and laboratory services as specialties whose claims can be batched when they fall within the same Category I CPT code section. For a radiology group, that means CT, MRI, and x-ray line items from the 70000 series can travel together in one dispute, subject to the 50 line item cap.

Not every provision is ready. CMS says the IDR Gateway will replace the current single-use web forms in the latter half of 2026, with additional Gateway functions expected in spring 2027. Requirements tied to those functions, including the new open negotiation and initiation steps, apply 90 days after CMS announces each one.

Which Radiology Practices Do the IDR Batching Rules Affect?

The IDR batching rules affect radiology groups that are out of network with a commercial health plan but read studies performed at in-network hospitals or imaging centers, along with groups that read emergency imaging. These are the situations where the No Surprises Act limits patient billing and sends payment disagreements to open negotiation and federal IDR.

Hospital-based radiology is the classic case. A patient chooses an in-network hospital, receives a CT, and has no say in which radiologist reads it. If that radiology group is out of network with the patient’s plan, the No Surprises Act protects the patient from a surprise bill, and the group’s remedy for a low payment is negotiation, then federal IDR if the plan is subject to federal rules.

Not every out-of-network claim qualifies. Medicare and Medicaid claims are outside this process, and services governed by a specified state surprise billing law may follow that state’s process instead of federal IDR. Self-funded employer plans generally fall under the federal process even in states with their own laws, which is why many groups juggle both systems at once.

Professional-only billing adds another wrinkle. Groups billing the professional component of a study, as explained in our modifier 26 billing guide, dispute only their own line items, so batches should be built around the group’s claims rather than the facility’s.

One question we hear constantly from radiology practice managers is whether a group with only a handful of out-of-network contracts needs to care. If those contracts cover busy hospitals, the line item volume can add up quickly.

Why the Departments Rewrote IDR Rules

The federal IDR process has drawn far more volume than regulators expected. Federal agencies and legal analysts have reported more than five million dispute submissions since the process launched in April 2022, which created backlogs and long waits for decisions. Earlier batching rules were also disrupted by litigation, and the new rules replace vacated provisions with a single framework.

Radiology sits near the center of that volume. As reported by Radiology Business on August 27, 2026, a Health Affairs analysis found that radiology accounted for roughly 23% of disputes and about $1.03 billion in awards, with median prevailing awards around 468% of the qualifying payment amount in 2025. Radiology groups have argued that the dispute count reflects high-volume, low-dollar services and restrictive batching, which is exactly what the new rules address.

The debate is not settled. On October 9, 2026, Radiology Business reported that a member of Congress had proposed changes to the No Surprises Act that radiology and other physician groups criticized as weakening independent arbitration. Insurers and some policymakers argue that IDR awards raise costs, while physician groups argue that arbitration is a needed check on low payments. As of October 2026, the proposal has not become law, and the November 1 batching rules apply regardless of how that debate ends.

In our experience matching providers with billing partners, radiology groups that track their out-of-network claims by payer and CPT section are the ones best positioned to benefit from larger batches starting in November.

What Do the New Batching Rules Mean for Radiology Revenue?

The new batching rules let radiology groups dispute more line items per filing, which lowers the labor and fee cost per disputed dollar. For high-volume, low-dollar imaging claims, that can turn disputes that were not worth filing into recoverable revenue, especially when combined with the lower $15 administrative fee.

Consider an illustrative scenario. A radiology group reads 400 eligible out-of-network CT and MRI line items in a quarter, such as CT abdomen and pelvis studies billed with CPT 74177 and chest CT studies billed with CPT 71250. Under a 25 line item limit, that volume requires 16 disputes. Under the 50 line item limit, it requires 8, cutting the number of filings, fee payments, and supporting packets in half. If the hypothetical gap between the plan’s payment and the group’s target is $40 per line item, the group has $16,000 a quarter at stake that it may have skipped disputing when batches were smaller.

Certified IDR entity fees still apply per dispute, and outcomes are never guaranteed, so the economics depend on each group’s claim mix. Still, fewer disputes covering more line items is a clear improvement for specialties built on volume.

This matters more as payment pressure builds elsewhere. Our breakdown of 2027 Medicare fee schedule changes for radiology shows why every recoverable commercial dollar counts.

Providers often come to us after realizing they stopped disputing low out-of-network payments years ago because the paperwork cost more than the recovery.

What Should Radiology Groups Do Before November 1?

Radiology groups should sort open out-of-network claims by the date open negotiation began, rebuild batching rules around line items and CPT sections, and assign a clear owner for open negotiation and IDR deadlines. Disputes that started before November 1 follow the old rules, so mixing the two creates rejections.

1. Sort open claims by date. Separate claims whose open negotiation began before November 1, 2026 from those starting on or after it.
2. Count line items, not claims. Build batches around qualified line items, since the 50 item cap applies to items, not claim forms.
3. Group by CPT section. Keep radiology line items together and avoid mixing them with laboratory or other service sections.
4. Calendar every deadline. Track the 30-business-day open negotiation period and the 4-business-day window to initiate IDR afterward.
5. Confirm federal eligibility. Screen out Medicare, Medicaid, and claims governed by a specified state surprise billing law.
6. Prepare for new remittance codes. Update payment posting so staff recognize the No Surprises Act RARCs on services furnished from January 1, 2027.
7. Assign one owner. Make one person or billing partner responsible for negotiation, filing, and fee payment deadlines.

Start with the payers that generate the most out-of-network volume, since a handful of plans usually account for most disputed line items. Pull 90 days of remittances for those plans, flag every line paid below your target, and check which ones are still inside the open negotiation window. That short list shows whether the new batching rules will pay off for your group and how many disputes to plan for in the first quarter.

Common Mistakes Under the New Batching Rules

The first mistake is assuming November 1 applies to every dispute filed after that date. The trigger is when open negotiation began, not when the dispute is filed. A claim whose open negotiation started in October still follows the old batching rules, even if the IDR filing happens in November.

The second mistake is counting claims instead of line items. A single claim can carry several qualified line items, and the 50 item cap counts each one. Groups that build batches by claim count can exceed the cap without realizing it and see the dispute rejected or split.

The third mistake is mixing CPT sections. The radiology batching allowance covers services within the same Category I CPT section. Adding a laboratory or anesthesia line item to a radiology batch breaks the grouping rule and can send the whole batch back for correction.

The fourth mistake is ignoring state law. Some claims belong in a specified state process rather than federal IDR, and filing them federally wastes fees and time. Check each payer’s plan type at the claim level rather than assuming by state. Self-funded employer plans usually stay federal, so payer type matters as much as state.

The fifth mistake is treating out-of-network recovery as a side project. Our coverage of radiology billing gaps and revenue leakage shows how small, untracked balances add up across a year. The most common issue we see providers run into is letting open negotiation deadlines lapse because no one owns them.

In-House vs. Outsourced IDR Management

Managing IDR in-house works for groups with a dedicated out-of-network specialist, clean claim data by payer and CPT section, and time to meet tight deadlines. Without those pieces, deadlines slip and eligible claims age out. The new batching rules reward groups that can organize data quickly, which favors billing teams that already run out-of-network workflows at scale.

Outsourcing also helps with the parts of the process that sit outside dispute filing: posting the new remittance codes correctly in 2027, tracking which payers ignore open negotiation, and reporting recovery rates so leadership can see whether disputes are worth the effort.

Ask any prospective billing company how it tracks open negotiation start dates, how it builds batches under the 50 line item cap, and how it reports IDR outcomes by payer. Our guide on how to find the right radiology medical billing service walks through the full evaluation. Many billing companies in our network also work inside the systems imaging practices already use, including eRAD RIS/PACS, athenahealth, and McKesson (Change Healthcare).

Radiology Bill Co is part of the Billing Service Quotes network, which has matched more than 2,000 providers across all 50 states, brings over 15 years of industry experience, and offers billing rates starting as low as 2.95%. Requests are reviewed by a real person, including Tim Daniels, Director of Strategic Accounts at Billing Service Quotes, who helps radiology groups connect with billing companies that understand commercial, out-of-network, and dispute workflows. Most groups are matched in as little as 30 minutes at no cost.

Frequently Asked Questions

Next Steps

• Tracking lost revenue? Read our report on radiology billing gaps and revenue leakage.
• Billing professional reads? Review the modifier 26 billing guide.
• Choosing a billing partner? See how to find the right radiology medical billing service.