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
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
| Step | You have | Counted in | Clock starts when |
|---|---|---|---|
| Payer pays or denies | 30 days | Calendar days | The payer has what it needs to decide the claim |
| Send the open negotiation notice | 30 days | Business days | You receive the payment or denial |
| Negotiate | 30 days | Business days | You send the notice (that day is day 1) |
| File for IDR | 4-day window | Business days | Business day 31 after you sent the notice |
| Agree on an IDR entity | 3 days | Business days | CMS receives your filing |
| Submit offers | 10 days | Business days | The IDR entity is selected |
| IDR entity decides | 30 days | Business days | The IDR entity is selected |
| Payer pays | 30 days | Calendar days | The decision is issued |
| Start another dispute, same payer, same or similar items | Wait 90 days | Calendar days | The 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.
| Date | |
|---|---|
| Negotiation ends | Wednesday, July 15 |
| Filing window opens | Thursday, July 16 |
| Last day to file | Tuesday, July 21 |
| Too late | Wednesday, 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
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