State Legislative Bills Report
As most state legislatures end their 2025 sessions and look to 2026, ACR staff is looking at how some radiology-specific bills they tracked fared this year.
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ACR Working with Allies to Fight Surprise Billing Independent Dispute Resolution Fee Increase
Jan. 13, 2023
The American College of Radiology® (ACR®) is fighting a 600% fee increase to file a No Surprises Act (NSA) Independent Dispute Resolution (IDR) claim. The NSA is a law passed in 2020 to protect patients from surprise medical bills. The NSA includes the IDR process between providers and insurers to dispute contested payments, with no monetary impact on the patient.
The Centers for Medicare and Medicaid Services (CMS) announced an amendment to its 2023 IDR fee guidance Dec. 23, raising the $50 fee it set in October to $350 in December. The ACR is advocating to preserve its members’ full access to a fair and affordable IDR process.
CMS said the reason for the increase was “supplemental data analysis and increasing expenditures in carrying out the Federal IDR process since the development of the prior 2023 guidance.”
The administrative fee is charged to each party at the beginning of the IDR process. This is in addition to the fee charged by the IDR entities, ranging from $200–$700 for single claim determinations and $268–$938 for “batches” or groups of similar claims determinations. Each party pays the IDR entity fee, which is refunded to the winning party. CMS’ administrative fee is not refunded to either party.
Given the fact that most radiology claims are for amounts less than $350, the 600% administrative fee increase essentially makes the IDR process cost prohibitive and inaccessible for radiologists.
The IDR administrative fee increase is the latest of many challenges faced by physicians in implementing provisions of the NSA by the Administration. In addition to pursuing legal challenges, the ACR will continue to work with the Congress and Executive branch to affect important and necessary changes.
If you have questions or for more information, contact Katie Keysor, ACR Senior Director of Economic Policy.
The Centers for Medicare and Medicaid Services (CMS) announced an amendment to its 2023 IDR fee guidance Dec. 23, raising the $50 fee it set in October to $350 in December. The ACR is advocating to preserve its members’ full access to a fair and affordable IDR process.
CMS said the reason for the increase was “supplemental data analysis and increasing expenditures in carrying out the Federal IDR process since the development of the prior 2023 guidance.”
The administrative fee is charged to each party at the beginning of the IDR process. This is in addition to the fee charged by the IDR entities, ranging from $200–$700 for single claim determinations and $268–$938 for “batches” or groups of similar claims determinations. Each party pays the IDR entity fee, which is refunded to the winning party. CMS’ administrative fee is not refunded to either party.
Given the fact that most radiology claims are for amounts less than $350, the 600% administrative fee increase essentially makes the IDR process cost prohibitive and inaccessible for radiologists.
The IDR administrative fee increase is the latest of many challenges faced by physicians in implementing provisions of the NSA by the Administration. In addition to pursuing legal challenges, the ACR will continue to work with the Congress and Executive branch to affect important and necessary changes.
If you have questions or for more information, contact Katie Keysor, ACR Senior Director of Economic Policy.
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