The dates below are a practical orientation based on current CMS materials—not a substitute for calculating the deadline for a specific dispute.
30 business days: open negotiation
CMS describes a required 30-business-day open-negotiation period between the provider or facility and the plan or issuer. Federal IDR cannot be initiated until that period has ended.
4 business days: initiate federal IDR
CMS states that a party generally must initiate the federal IDR process within four business days after open negotiation ends. Department-issued extensions and special circumstances can affect a particular deadline, so the CMS Notices page belongs in the review workflow.
3 business days: report a post-initiation agreement
If the parties agree on an out-of-network rate after IDR is initiated but before a determination, CMS says the initiating party must provide the required agreement information within three business days.
30 calendar days: payment after a determination
CMS states that the parties must abide by the certified IDR entity’s decision and that payment must be made within 30 calendar days. An award record and a payment record should therefore be tracked as separate events.
2026 changes require implementation checks
The 2026 operations final rules introduce updated communications, eligibility timelines, batching rules, fees, and the IDR Gateway. Some changes depend on effective dates, portal functionality, or further guidance. Verify the current form and implementation status before changing a production workflow.
A reliable deadline record includes
- The source event and source document
- Whether the unit is business days or calendar days
- The calculated date and the person or system that calculated it
- Any extension, portal notice, or exception relied upon
- An owner, reminder, completion record, and escalation path