# No Surprises Act IDR Support Services

> Independent Dispute Resolution submission support under the No Surprises Act. Additional-circumstances factors cited from the record and claim file.

Canonical page: https://medrecords.ai/solutions/no-surprises-act-idr-support/

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NO SURPRISES ACT IDR SUPPORT

## The IDR submission, built from the record — acuity, complexity, training, all cited.

No Surprises Act IDR support prepares the offer submission from the file itself. The additional-circumstances factors at §149.510(c)(4)(iii)(C) are the entire argument, so we pull patient acuity, case complexity and the clinical detail behind them out of the record and the claim file, cited page by page, into a submission a certified IDR entity can read in one pass.

[Test a file ](https://medrecords.ai/test-a-file/?src=no-surprises-act-idr-support)
 [Book a demo](https://medrecords.ai/demo/?src=no-surprises-act-idr-support)
Click any row → the source page it cites
Dispute file · Case #IME-4812
 cited
Adams, Timothy
 · IDR dispute file
342 pp / 2 productions received
 logged
11 duplicate pages removed
 free
p.140 — wrong patient
 quarantined
Pages 342
 Documents 27
 Cited 100%

### The rulebook is published. So is every determination.

We do not build for a case type until we can name the standard that defines a correct output and the person who grades the file against it. Federal IDR gives us both in writing, then publishes the scoreboard.

That makes this the cleanest feedback loop in claims work: a binary decision, on a published clock, against a factor list you can read in the regulation.

The rulebook and the referee
The rulebook
- 45 CFR §149.510 — the Federal Independent Dispute Resolution process, enacted through the No Surprises Act in the Consolidated Appropriations Act, 2021
- §149.510(c)(4)(iii)(C), the additional-circumstances factors: level of training, experience and quality outcomes; patient acuity and case complexity; teaching status and case mix; market share; prior contracting history between the parties
- CMS Federal IDR Guidance, which sets the submission mechanics
- The Texas Medical Association I–IV litigation, which vacated the presumption in favour of the qualifying payment amount and left the factor list carrying the argument

The referee
- The certified IDR entity, which picks one of the two submitted offers — no splitting the difference, no partial award
- The decision comes back in writing, in days, and names the factors it turned on
- CMS publishes every determination in quarterly public-use files, so a win rate is measurable from published data rather than estimated

Provider-side IDR services typically take 20–35% of the award, across roughly 2.6 million disputes a year

 Flat 10¢/page here, duplicates free
Dispute file · Case #IME-4812
 cited 100%
Productions342 pp / 2 productions · 11 deduplicatedlogged
Patient acuityPulled from the clinical chart, page-citedcited
Case complexity7 visits, each tied to its source pagecited
Handwritten pagesRead in full, not skippeddegraded
Factors extracted · cited 100% · no offer set here
What the file actually looks like

### Twenty pages or three hundred, and millions of disputes behind them.

A single IDR dispute file runs 20 to 300 pages, with about 160 in the middle, and it rarely arrives as one production. The claim record comes out of the billing system, the clinical detail comes out of the chart, and the payer correspondence comes back separately. The acuity and complexity facts that decide the case are spread across all three.

Volume is the other half of the problem. Federal IDR now runs at roughly 2.6 million disputes a year and climbing: 1.2 million in the first half of 2025, twice the same period in 2024, and 4.8 million cumulative since 2022. CBO forecast 17,000 a year when the process was designed, off by a factor of 150. The backlog sits near 430,000.

The pages themselves are not clean. Faxed operative notes, handwritten anesthesia records, and the same discharge summary repeated in every production. Duplicates are free here, so a batched submission costs what its distinct pages cost.

20–300
pages in a dispute file
4.8M
disputes filed since 2022
~430k
still queued in the backlog
What we'd build with you

### One file first. The build comes after.

01

#### Send one real file

One dispute, as it already exists: the claim record, the clinical chart, the payer correspondence. In the demo case that is 342 pages across 2 productions, with a wrong-patient page quarantined before the read starts.

02

#### We return the read

Patient acuity, case complexity, level of training and the clinical detail behind each one, extracted and cited to the page it came from. You see the output before anything is scoped or signed.

03

#### We scope the build

If the read holds up, we scope the template against the factors at §149.510(c)(4)(iii)(C): your submission format, your fields, your batching conventions, your specialty's language.

04

#### You run it

Your team files. The platform organizes, cites and surfaces what the record says. The offer, the eligibility position and the argument stay with the people who sign them.

Audit trail · Case #IME-4812
 exportable
08:12Dispute file received · 342 pp / 2 productionssystem
08:3111 pages deduplicatedsystem
08:44p.140 flagged — wrong patientsystem
08:54Factor extraction complete · cited 100%system
09:20Draft reviewed · citations verifiedreviewer
09:26Exported · offer set and filed off-platformreviewer
Every access logged · file deleted 30 days after delivery
Why Medrecords AI

### The rules the platform never breaks.

EVERY LINE CITED
CASE #IME-4812 · ADAMS, T.342 pp
2/14 — ER visit, right knee
 p.4
4/18 — arthroscopic surgery
 p.61
p.140 — wrong patient
 quarantined
Medrecords AI
Read every page · cite every line

#### HIPAA, under a signed BAA

Every file is handled under our Business Associate Agreement, from the first byte.

#### Never trains a model

Your records are never used to train any AI model — ours or anyone else's.

#### Every line cited

If we can't cite it, we don't say it. Every sentence links to its source page.

#### Deleted after delivery

Files are deleted 30 days after delivery, with a full audit log of every access.

Powered by the platform

### Four capabilities behind every IDR submission.

IDR submission preparation is one deliverable of the same platform that reads, sorts and cites the whole record.

[

#### Claims Billing Ledger

Every billed line in the dispute traced back to the page that documents it, so the claim file and the chart tell the same story.

IN ACTION · 342 pp / 2 productions → every figure traced to a page
](https://medrecords.ai/product/claims-billing-ledger/)
 [

#### Medical Bill Review

Billed charges read against what the record documents, so the billed service and the documented service can be compared line by line.

IN ACTION · billed line → documented service, side by side
](https://medrecords.ai/product/medical-bill-review/)
 [

#### Medical Chronology

The treatment timeline behind acuity and complexity builds itself from the chart, synced to every source page.

IN ACTION · 7 visits since 4/02, each cited to its page
](https://medrecords.ai/product/chronology/)
 [

#### Custom Report Builder

Your submission template, filled in from the record — the same fields every time, in the format your reviewers expect.

IN ACTION · 38 template fields, filled from the file
](https://medrecords.ai/product/custom-report-builder/)
FAQ

### No Surprises Act IDR support, answered.

We read the dispute file and return the additional-circumstances factors at §149.510(c)(4)(iii)(C) in a form a certified IDR entity can read in one pass: patient acuity, case complexity, level of training and experience, and the clinical detail behind each one, every line cited to the page it came from. We organize and cite the record. The offer you submit, and the argument you make for it, stay yours.

No. Eligibility and batching are determinations your team makes and the certified IDR entity confirms. What we do is surface what the file actually says: dates of service, service and modifier codes, provider and facility detail, and where the same facts repeat across productions. The people making those calls work from the cited record instead of from memory.

We do not calculate a qualifying payment amount and we do not opine on whether the payer's is correct. After the Texas Medical Association litigation vacated the QPA presumption, the additional-circumstances factors carry the argument, and those factors are record facts. We extract and cite them. Whether they support a QPA challenge is your counsel's call, not ours.

No. Medrecords AI does not retrieve records from providers or facilities. You bring the records you already have — review starts in minutes from upload. Retrieval vendors take days; you can keep yours and still cut the review to minutes.

No. We do not score case merit, predict determinations, or set an offer. CMS publishes every IDR determination in quarterly public-use files, so a win rate is measurable from published data — but that measurement, and the offer that follows it, belong to your team. What we return is the cited record behind the submission.

### Send one file. We'll tell you what we can read.

No obligation. If the case type is buildable we'll scope it; if it isn't, we'll say so.

[Test a file ](https://medrecords.ai/test-a-file/?src=no-surprises-act-idr-support)
 [Book a demo](https://medrecords.ai/demo/?src=no-surprises-act-idr-support)
[All claims integrity work →](https://medrecords.ai/solutions/claims-integrity/)
Related case types: [Provider fraud record review](https://medrecords.ai/solutions/provider-fraud-record-review/) · [Medicare audit response](https://medrecords.ai/solutions/medicare-audit-response/) · [All case types →](https://medrecords.ai/solutions/case-types/)
