Federal IDR guides

How long do I have at each step of federal IDR?

Every federal IDR deadline in one table, with business days vs calendar days and what starts each clock. Plus the one window that kills claims.

Verified September 10, 2026

All federal IDR guides

Short answer

You get 30 business days to send the open negotiation notice, 30 business days to negotiate, then a 4-business-day window to file. After that: 10 business days to submit offers, 30 business days for a decision, 30 calendar days for the payer to pay.

Most missed deadlines come from two mistakes. Mixing up business days and calendar days. And starting the clock on the wrong day.

Send the notice

30

Business days from the EOB

Negotiate

30

Business days from the notice

File for IDR

4

Business day window, days 31 to 34

Payer pays

30

Calendar days from the decision

The deadlines

How long do I have at each step of federal IDR?: The deadlines
StepYou haveCounted inClock starts when
Payer pays or denies30 daysCalendar daysThe payer has what it needs to decide the claim
Send the open negotiation notice30 daysBusiness daysYou receive the payment or denial
Negotiate30 daysBusiness daysYou send the notice (that day is day 1)
File for IDR4-day windowBusiness daysBusiness day 31 after you sent the notice
Agree on an IDR entity3 daysBusiness daysCMS receives your filing
Submit offers10 daysBusiness daysThe IDR entity is selected
IDR entity decides30 daysBusiness daysThe IDR entity is selected
Payer pays30 daysCalendar daysThe decision is issued
Start another dispute, same payer, same or similar itemsWait 90 daysCalendar daysThe decision is issued

A business day is any weekday that is not a federal holiday. Thirty business days is about six weeks.

Watch out

The window that kills claims

The 4-day filing window. It opens on business day 31 after you send the notice and closes on day 34. File early and the portal rejects it. File late and the claim is dead.

Count the day you send the notice as day 1. Count it as day 0 and every date after it slips a day. That is enough to miss the window.

There is one exception, and it is easy to miss. If your negotiation period ends while a 90-day cooling-off period from an earlier decision is still running, you get 30 business days from the end of the cooling-off period instead of four. Everything else runs on the four-day window.

Worked example

Notice sent Tuesday, June 2, 2026. Two holidays fall in the period: Juneteenth and the observed July 4.

How long do I have at each step of federal IDR?: Worked example
Date
Negotiation endsWednesday, July 15
Filing window opensThursday, July 16
Last day to fileTuesday, July 21
Too lateWednesday, July 22

Three "30 days" that are not the same

The IDR entity has 30 business days to decide. The payer has 30 calendar days to pay after that. A settlement during IDR is paid in 30 business days. Same number, different clocks.

If you miss one

The claim is time-barred. It is not ineligible. The law still applied and the patient is still protected from balance billing. You lost the IDR remedy, nothing else.

CMS can give you more time if something outside your control caused the miss, like a portal outage or a payer that sent a half-finished denial. Ask through the IDR portal. The one deadline CMS will not extend is the payer's 30 days to pay.

Payer deadlines are soft. Yours are hard.

The payer's deadline to pay or deny, and its duty to send the QPA, are rarely enforced. Plan as if they never will be.

Sources

45 CFR 149.510(b) and (c); 45 CFR 149.110, 149.120, 149.130. CMS Federal IDR portal, day-count behavior confirmed July 2026.

Every number on this page comes from public CMS files or the federal rule. Our methodology explains how we count. Questions? sales@recoursehealth.com

Your data, not the national average

See how your group's IDR record compares.

A free report card built from the same CMS files, measured at the group level. Nothing needed from you.

Request your free report card