Trump Administration Finalizes No Surprises Act IDR Disclosure and Process Rules

WASHINGTON — The Trump administration published final rules overhauling parts of the federal independent dispute resolution process created by the No Surprises Act, the Federal Register showed on June 4, 2026.

The regulation, signed by President Donald Trump, affects every group health plan and health insurance issuer offering group or individual coverage that must comply with surprise-billing protections. It reaches millions of enrollees and thousands of providers who deliver emergency services, air ambulance transports and other out-of-network care protected under the 2020 law.

The rule, issued jointly by the Office of Personnel Management, Treasury Department and Internal Revenue Service under regulation IDs 0938-AV15, 1210-AC17, 1545-BQ55 and 3206-AO48, takes effect August 3, 2026. It replaces earlier interim requirements with mandatory use of standardized claim adjustment reason codes and remittance advice remark codes on every paper or electronic remittance advice sent to entities lacking a contractual relationship with the plan or issuer.

Plans must now include additional specified information alongside initial payments or notices of denial for items and services subject to the No Surprises Act.

Operationally the rule defines bundled payment arrangements, revises criteria for batched disputes, shortens or clarifies the open negotiation period before IDR initiation, updates the dispute eligibility review process, and sets new rules for collecting administrative fees and certified IDR entity fees.

It also expands the circumstances under which parties may receive extensions of certain timeframes due to extenuating circumstances. These changes replace the prior regulatory text that had governed the federal IDR system since its initial implementation after the Consolidated Appropriations Act, 2021.

Downstream, providers and plans must reprogram claims systems and update compliance procedures before the August 3 effective date. Certified IDR entities will apply the new batching and bundling definitions to every dispute filed after that date, directly affecting how many disputes qualify, the fees parties pay, and the speed of resolution.

Plans must begin using the prescribed CARC and RARC codes on all applicable remittances immediately upon the effective date, or risk procedural rejection of their payments. The rule contains no comment period because it is already final.

This document constitutes the latest formal revision to the federal IDR process first established under the No Surprises Act provisions of the Consolidated Appropriations Act, 2021. The 182-page final rule follows multiple rounds of prior rulemaking and guidance that had left certain disclosure, batching and fee requirements in interim status.