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Certified IDR entities: selection and conflicts

The certified IDR entity decides your dispute. Selection is a three-business-day negotiation between two parties who both want a favorable arbiter — and most providers do not use the leverage they have.

What a certified entity is

A certified IDR entity is an organization certified by the Departments of Health and Human Services, Labor, and Treasury to conduct federal independent dispute resolution. It is not a court and not a government body. It reviews both submitted offers, applies the statutory factors, and picks one. It cannot invent a third number.

The current roster of certified entities is published and maintained by CMS, and it changes — entities are added, suspended, and withdraw. Always work from the live list rather than a cached one.

How selection works

  • The initiating party names a proposed certified entity when it initiates.
  • The non-initiating party has 3 business days to agree or propose an alternative.
  • If the parties do not agree within the window, the Departments select an entity.
  • The selected entity must attest that it has no disqualifying conflict of interest with either party.
The overlooked leverage. As the initiating party, you name first. Entities differ measurably in throughput, in how they handle batched disputes, and in how thoroughly they engage with supporting documentation. Naming deliberately is free.

Conflicts of interest

Certification requires entities to be free of financial or ownership relationships with either disputing party, and to screen individual reviewers for the same. A party that believes a conflict exists may object. In practice, conflicts most often surface where an entity has a relationship with a large payer or a national billing organization — worth checking when you are a small group filing against a dominant plan.

What the entity charges

Entity fees are set within ranges published by the Departments and vary by entity and dispute type. Current ranges run roughly $200 to $840 for single determinations and $268 to $1,173 for batched determinations, alongside the $15 administrative fee per party. The batched range is why batching is the central economic decision in any high-volume dispute program: one entity fee across up to 50 line items.

What the entity will and will not consider

The entity must consider the QPA and may consider the permitted additional factors: provider training and experience, market share of the parties, patient acuity and case complexity, teaching status and case mix of the facility, and prior contracted rates between the parties over the preceding four years. It may not consider usual and customary charges, billed charges, or public payer rates. Submissions that lead with billed charges are arguing on excluded grounds.

Fee ranges reflect the CMS final rule published June 4, 2026. Verify the current certified entity list and fee schedule before each filing cycle.

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Entity selection, conflict screening, and offer construction are part of the filing service. Start with a free eligibility review.

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