Independent Dispute Resolution (IDR) Services

That Turn Low Out-of-Network Payments Into Fair Reimbursement

Is a plan paying your out-of-network claims at or near the qualifying payment amount (QPA) and calling it done? You can push back. Vigilant Billing is an out-of-network billing company working with anesthesia, emergency medicine and surgical groups, and pushing back is a big part of what we do, through open negotiation and No Surprises Act arbitration. We run the federal independent dispute resolution (IDR) process from the first notice to the final award, and every eligible claim gets filed before its deadline passes.

Can my claim go to IDR?

88%
IDR dispute win rate
98.8%
Net collection rate
1.12%
Denial rate
4 to 6 weeks
Typical credentialing turnaround

Why Out-Of-Network Groups Are Leaving Money On The Table

Since the No Surprises Act took effect, plenty of health plans have settled into a routine. They pay out-of-network claims at or below the QPA and wait for the deadlines to pass. The windows are short. Open negotiation has to start within 30 business days of the initial payment or denial, and IDR has to be filed within 4 business days after negotiation ends. If either one slips by, the plan’s number is the one you’re stuck with.

Disputing works. Our own disputes are won 88% of the time, and the national numbers point the same way. In federal data for the second half of 2025, providers came out ahead in about 85% of IDR payment determinations, and in most of them the award was higher than the QPA. A group that doesn’t dispute is accepting the lowest figure anywhere in the process.

This is where we usually see the money go missing:

01

Initial payments posted at the QPA, with nobody following up

02

Denied out-of-network claims written off, even though they could have gone to IDR

03

Open negotiation notices that were never sent, or went out after day 30

04

Claims batched the wrong way and rejected as ineligible

05

No one watching the 30 calendar days the plan has to pay an award

Recent IDR Results For An Anesthesia Client

From July through September 2026, independent reviewers decided 48 of our disputes for a single Arizona anesthesia group. The group won 34. Across those wins the awards came to $264,718, on claims where the plans had first paid $12,274. That’s more than 21 times the original payment. The median time from filing to decision was 92 days.

A few of the individual cases:

Anesthesia case
Plan's first payment
IDR award
Lower abdominal procedure(00840)
$820
$35,613
Upper abdominal laparoscopic procedure(00790)
$1,316
$31,125
Total shoulder replacement(01638)
$845
$19,238
Upper GI endoscopy(00731)
$139
$7,700
Screening colonoscopy(00812)
$128
$5,125
Arizona anesthesia groupJUL – SEP 2026
34of 48 won
First paid by plans$12,274
Awards on wins$264,718
21×+the original payment
92 daysmedian filing to decision

The full Anesthesia IDR Case study walks through the work behind these numbers, including what we learned from the disputes that were dismissed.

The Work Behind Every IDR Win

Filing the dispute is the easy part. Most No Surprises Act billing disputes are won or lost in the work around the filing. You need to know what your services are worth in your market, catch every deadline on every claim, and show the arbitrator, with evidence, why the plan’s number is too low. Our independent dispute resolution services cover all of it.

Market-Based Fee Schedule Review

It starts with your charges. We set market rate data, including the in-network rates plans must publish under federal price transparency rules, beside your payment history and regional benchmarks. Then we revise your fee schedule where needed, so every charge and offer can be defended. Offers not tied to the market rarely win.

Claim Screening And Eligibility

We go through every out-of-network remit and flag the claims the No Surprises Act protects. That covers emergency services and non-emergency ancillary services at in-network facilities, such as anesthesia, radiology, pathology and assistant surgery. Claims that belong in a state process or an appeal are pulled out and sent there.

Open Negotiation

The open negotiation notice goes out inside the 30-business-day window, with every required data element included. We log each response from the plan and follow up whenever it goes quiet. If the plan shows any willingness to move, we push for a fair settlement well before the claim needs to reach arbitration.

Every Claim Tracked To The Finish

Each claim runs on its own deadlines: 30 business days to start open negotiation, 30 business days of negotiation, then 4 business days to file. Offers are due once the arbitrator is selected, and the plan then has 30 calendar days to pay an award. We track every one of those dates, claim by claim, so none are missed.

The Case For Why You Should Be Paid

The qualifying payment amount (QPA) is one factor. The certified independent dispute resolution entity also weighs complexity and acuity, provider training and experience, market share and contracting history. We back each one with market rate data and case detail: units, time and physical status for anesthesia, and levels and approach for surgery.

Filing, Batching And Award Collection

We file through the federal IDR portal, attest to eligibility, and batch related claims wherever the rules allow. Then we make sure the plan actually pays. Each award is tracked until the money arrives, late payers are followed up and reported, and every dollar is posted back to the original claim it belongs to.

Can A Denied Claim Go To IDR?

Yes, if the plan denied payment and not coverage. Under the No Surprises Act, the clock can start with an initial payment or with a notice of denial of payment. So a $0 or denied claim for a covered, NSA-protected service can be disputed just like a low payment. The reason on the remit tells you which path the claim takes.

We read the claim adjustment reason codes (CARC) and remittance advice remark codes (RARC) on every out-of-network denial and route each claim within the same week. One detail that often gets missed: if an appeal turns a coverage denial into a payment at the QPA, that payment opens a new open negotiation window. The claim can still end up in IDR.

Out-of-network remit
CARCRARC
Denial of payment
Open negotiation → IDR
Coverage denial
Appeal
Appeal paid at the QPA opens a new open negotiation window
Denial type
Example
Path
Denial of payment on a covered service
Paid $0, or denied as out-of-network at an in-network facility
Open negotiation, then IDR
$0 applied to the patient's deductible
Plan sets its rate and the patient owes all of it
Open negotiation, then IDR on the rate
Plan says the claim is not NSA-eligible
Wrong facility network status, or the wrong state forum cited
File with an eligibility attestation; the IDR entity decides
Coverage or medical necessity denial
Not medically necessary, not a covered benefit, no prior auth, patient not eligible
Internal appeal, then external review
Coding or billing denial
Bundling, missing modifier, invalid code, timely filing
Correct and resubmit, or appeal
Federal IDR feesWIN OR LOSE
Administrative feePaid by Vigilant
Arbitration feePaid by Vigilant
You pay$0

You Never Pay IDR Fees Out Of Pocket

Every federal IDR dispute comes with administrative and arbitration fees, and the side that loses pays the arbitration fee. When Vigilant handles your disputes, we pay all of those fees, whether we win or lose. You won’t get a separate bill for filing or arbitration. The risk of the dispute sits with us, which is also why we only file claims we believe in.

When A Plan Won't Play By The Rules

Some plans ignore open negotiation notices. Others claim an exclusion that doesn’t apply, or simply sit on an award. When that happens, we document every contact and escalate. That can mean the federal No Surprises Help Desk, or the state insurance department when the plan is state-regulated. We’ve taken both routes for anesthesia groups in Arizona and Nevada.

Document every contact
Escalate
Federal No Surprises Help Desk
State insurance department
ArizonaNevada

IDR Built For Anesthesia, Emergency And Surgical Specialties

Generic IDR for providers tends to treat every claim the same way, but how an offer explains the service has a lot to do with how it’s decided. Our team has billed anesthesia and spine claims for close to a decade. We know how to present base units, time and physical status on an anesthesia claim, and how to explain what makes a multi-level fusion with neuromonitoring and an assistant surgeon complex.

IDR for anesthesia

Anesthesiologists and CRNAs working at in-network hospitals and ambulatory surgery centers (ASCs) can’t use notice and consent, so IDR is the main route to fair payment. See our anesthesia billing services.

IDR for emergency medicine and critical care

Emergency services are protected whatever the network status, and they make up the largest share of disputes in the federal system.

Spine and orthopedic surgery

Assistant surgeons, intraoperative neuromonitoring and emergency spine cases come up often as IDR candidates. See our spine surgery billing services.

Line items per batched claim

25→50

Batching changes apply from

Nov 1, 2026

Plans respond by the

15th business day
AnesthesiaRadiologyPathologyLab

What Changed In 2026

The federal IDR operations final rule came out in May 2026, and it changes several things providers deal with every day. Batched IDR claims can now hold up to 50 line items instead of 25, and anesthesia, radiology, pathology and lab services billed under the same or similar codes can be batched across patients. These batching changes apply to disputes whose open negotiation period begins on or after November 1, 2026.

Open negotiation is also moving into the federal portal, with plans required to respond by the 15th business day, although that part is being rolled out in stages. Plans will have to register with the federal system, and once the Departments issue guidance, they’ll have to use standard claim adjustment and remark codes on out-of-network claims. Expect more disputes overall, and less tolerance for messy paperwork.

Federal IDR Vs State Arbitration In Nevada, Arizona And Texas

Not every out-of-network claim belongs in the federal process. Self-funded employer plans covered by ERISA go through federal IDR. Some fully insured plans in states with their own surprise billing law, Texas among them, use a state arbitration process instead. We sort each claim into the right forum before any deadline starts running. We work with groups in Nevada, Arizona and Texas every day, Las Vegas anesthesia practices included. We know the major regional payers and the third-party administrators behind the local self-funded plans.

Self-funded employer plans (ERISA)
Federal IDR
Fully insured plans in states with their own surprise billing law
Nevada seal Nevada
Arizona
Texas

How Pricing Works

Our independent dispute resolution services are priced around results. Your standard billing fee already covers billing, follow-up and open negotiation on every out-of-network claim. If a claim goes to IDR, our fee comes only out of the extra money recovered above what the plan first paid. If the award doesn’t improve on that payment, you owe nothing for the IDR work, and the filing and arbitration fees stay with us. Before you sign anything, we’ll walk you through the numbers using your own claims.

No Surprises Act compliant$0 upfront filing fees

CLM-20481 OON CLAIM · CPT 99285
Award issued

Plan's initial
payment

$300

IDR award

$6,000

Extra money
recovered

$5,700
$300
$6,000
Covered by your
standard billing fee
Our IDR fee is derived from
this source

How To Get Started

Send over your last 90 days of out-of-network remits. 835 files work, and so do EOBs.

Give us a few business days. You’ll get back a list of every claim, whether it’s eligible, and which deadlines are still open.

Tell us which claims you want to dispute. Open negotiation goes out that same week.

Keep in mind that the 30-business-day clock runs whether anyone is working the remit or not.

About Vigilant Billing:

Vigilant Billing (Vigilant Medical Group LTD CO) is an anesthesia and physician revenue cycle management company headquartered in Mesquite. The company’s leadership has worked in anesthesia revenue cycle management since 2016. Across its clients, net collections run at 98.8% and the denial rate is 1.12%. The company wins 88% of IDR disputes, and credentialing typically takes 4 to 6 weeks.

Billing and coding for anesthesia groups

Credentialing for anesthesiologists and CRNAs, and for certified anesthesiologist assistants (CAAs) in states that allow them

Coverage planning and stipend numbers
for hospitals and surgery centers

No Surprises Act open negotiation
and independent dispute resolution

FAQs

Frequently Asked Questions

Still have a question about your claims?

Independent dispute resolution (IDR) is the federal arbitration process the No Surprises Act set up for payment disputes between out-of-network providers and health plans. If open negotiation doesn’t produce a deal, either side can file. Each side then submits a final payment offer, and a certified IDR entity chooses one of the two. That decision is binding.

We usually finish credentialing in 4 to 6 weeks. Hospital privileges and payer enrollment both start the day you sign the provider and run at the same time, instead of one after the other.

Each CRNA is enrolled with Medicare in PECOS, with benefits reassigned to the group, and linked to the group’s contracts with commercial payers. Claims only pay correctly when each CRNA and AA is enrolled and linked to the group’s tax ID.

Yes, within a care team model. CAAs always work under an anesthesiologist’s medical direction, so each AA claim carries QX and has to match the directing anesthesiologist’s claim. State rules apply: Nevada and Texas allow CAAs to practice (as of 2025), but Arizona doesn’t license them.

QK is billed by an anesthesiologist directing several rooms at once (up to four under Medicare’s rules), and QY if it’s only one case. QX is billed by the CRNA or anesthesiologist assistant working under that direction. QZ is for a CRNA working without medical direction.

Often, yes, especially when in-house billers or a general billing firm handle the claims but not everything around them: time and units, modifiers, credentialing, facility coverage, stipends and out-of-network rules. A team that works in anesthesia all day covers those gaps.

It depends on how many rooms run and for how long, any call, OB or trauma coverage, and your care team ratio. For example, six rooms for ten hours a day at 1:3 could be covered by two anesthesiologists directing six CRNAs or AAs, plus one relief provider. A personally performed model would need six anesthesiologists.

Not for an ancillary service at an in-network facility. Under the No Surprises Act you can’t balance bill the patient or use notice and consent. The claim goes through open negotiation and, if needed, independent dispute resolution.

Not for an ancillary service at an in-network facility. Under the No Surprises Act you can’t balance bill the patient or use notice and consent. The claim goes through open negotiation and, if needed, independent dispute resolution.

Not for an ancillary service at an in-network facility. Under the No Surprises Act you can’t balance bill the patient or use notice and consent. The claim goes through open negotiation and, if needed, independent dispute resolution.

Stop accepting the QPA as the final word

Send us your out-of-network remits and we’ll show you, claim by claim, what’s eligible and how much is at stake. The review is free. We also take on only a limited number of new IDR clients each quarter, so every deadline gets the attention it needs.