The QPA is an opening offer, not the final word.
Under the No Surprises Act, out-of-network physicians can contest low payments through open negotiation and federal independent dispute resolution (IDR). We run the process end to end for 10% of what we recover, and nothing if we don't win.
Five steps, with deadlines that don't move.
Most physician groups lose these disputes by default: the windows are short and the paperwork is heavy. We track every deadline from the moment the remittance posts.
Initial payment
The plan pays (often near its qualifying payment amount, the QPA) or denies.
Open negotiation
30 business days to negotiate, started by a notice sent within 30 business days of the payment.
Federal IDR
If talks fail, IDR must be started within 4 business days after negotiation ends.
Offers and evidence
Both sides submit an offer with evidence: training, acuity, market share, past contracted rates.
Decision
The certified IDR entity picks one offer. Payment is due within 30 calendar days.
Out-of-network physicians at in-network facilities.
- Anesthesiology groups
- Surgeons and assistants at in-network hospitals and ASCs
- Emergency and hospitalist services
- Radiology, pathology and neurophysiology (IONM)
Federal IDR applies to plans subject to the No Surprises Act. Some state-regulated plans follow a state process instead (Texas has its own). We confirm eligibility for each claim before filing.
Pricing for IDR work
- No fee if a dispute is lost or abandoned
- Federal IDR administrative and certified-entity fees are set by CMS, paid to the government and the IDR entity, and are separate from our fee
- Batching of similar claims where the rules allow
No Surprises Act insights
No Surprises Act questions
What is the No Surprises Act?
A federal law, in effect since January 2022, that protects patients from most surprise out-of-network bills for emergency care and for non-emergency care by out-of-network providers at in-network facilities. Providers and plans resolve payment disputes through open negotiation and, if needed, independent dispute resolution (IDR).
What is the QPA?
The qualifying payment amount: generally the plan's median contracted rate for the same or similar service in the same geographic area, indexed for inflation. Plans often pay at or near it; it is one factor in IDR, not the final answer.
How long do we have to start open negotiation?
30 business days from the day you receive the initial payment or notice of denial. Open negotiation then runs for 30 business days.
When can we file for IDR?
Within 4 business days after the open negotiation period ends without agreement.
Does IDR apply to all plans?
It applies to plans subject to the No Surprises Act. Some state-regulated plans follow a state dispute process instead, and Medicare and Medicaid are not part of federal IDR.
10 minutes. One screen. Your numbers.
A short Google Meet with Rohit to look at where your revenue stalls and whether contingency recovery makes sense for your practice. No software change, nothing to pay up front.