No Surprises Act FAQs

The CMS Portal has recently added the requirement that parties initiating a dispute must submit proof of the open negotiation period and notice of initiation being completed successfully. FHAS recommends when submitting documentation for these requirements to provide the following: Date/Time stamp of the open negotiation period and notice of initiation, method of delivery and address (physical or electronic), and the open negotiation period and notice of initiation themselves.

When submitting a dispute outside of the customary 4-day window of initiation, the CMS Portal requires documentation for each specific reason. If the reason is regarding a now expired cooling-off period, proof should include the email containing the previous dispute number and a statement from the IDRE that the dispute is closed due to the cooling-off period not expiring. Likewise, if the reason is regarding batching, proof should include the email containing the previous dispute number and a statement from the IDRE that the dispute is closed due to incorrect batching.

FHAS also recommends that initiating parties submit the Notice of Denial of Payment or Notice of Payment for each service in the dispute. This allows for a more streamlined processing of any objections made.

When a non-initiating party receives an entity selection response email, any objections to the eligibility of the item(s) and/ or service(s) should be entered on the entity selection response email. Further, the Federal CMS portal requires documentation supporting the statement regarding eligibility to be submitted along with the objection. If a party does not know what documentation is needed, contact our communication team via email at IDRE@fhas.com, or via phone at (570) 779-5122.

If a party believes items/services being disputed are ineligible, an objection should be submitted within the IDRE Selection Response Form that is automatically sent to a party when a dispute is initiated in the CMS Portal. This form is sent to the email provided by the initiating party. The email provided to the IDRE should originate from the email stated on the Notice of Denial of Payment or Notice of Payment.

Objections should not be made after the selection of the IDRE. However, if a party believes that the dispute is not eligible after IDRE selection, any concerns can be brought to the attention of FHAS by contacting our communication team via email at IDRE@fhas.com, or via phone at (570) 779-5122.

​If a party believes a dispute is ineligible, and FHAS has requested an offer and payment, it is recommended to still submit payment and an offer. However, any objections should be made known through contacting FHAS, and our team will process the concern accordingly and timely. Failure to submit an offer or payment will result in an unfavorable outcome for the party.

If a party wants to withdraw a dispute, they can contact the FHAS communication team via email at IDRE@fhas.com with the dispute number and reason for withdrawal.

Please note that any withdrawal request must contain consent from both parties involved with a dispute. This consent must be obtained in writing (email, letter, etc.).​

According to CMS rules and regulations if a dispute is withdrawn, then the admin fee is retained, as well as half of the entity fee from each party.​

When you receive an additional information request, FHAS lists the specific documents needed to determine eligibility of the dispute. All documentation should be submitted either via replying to the email, or submitting confidential documentation through the ShareFile link, which is also listed on the additional information request.

If you have any other questions regarding what additional information to request, please contact FHAS’ communication team via email at IDRE@fhas.com, or via phone at (570) 779-5122.

Payment for a dispute can be made in multiple ways; ACH, e-check, paper check, and credit card. If your party has a high volume of disputes, easier payment arrangements can be made by contacting FHAS’ finance team via email at IDREpayments@fhas.com, or via phone at (570) 779-5122.

The request for payment and the request for offer submission should be received by both parties on the same day. If you do not receive one of the requests mentioned on the same day, contact FHAS’ communication team via email at IDRE@fhas.com, or via phone at (570) 779-5122.

FHAS will request the submission of an offer at the same time a request for payment is made. An email will be sent from CMS notifying you that an offer is due for your dispute which will contain a link. This link will take you to where you will fill out your CMS Notice of Offer form, as well as submit any additional information seen fit.

Parties should ensure that the offer amount is correctly entered for any item(s) and/ or service(s) into the CMS Notice of Offer Template.

The request for payment and the request for offer submission should be received by both parties on the same day. If you do not receive one of the requests mentioned on the same day, contact FHAS’ communication team via email at IDRE@fhas.com, or via phone at (570) 779-5122.

If any party has a concern regarding the review of a dispute, please contact FHAS’ communication team via email at IDRE@fhas.com, or via phone at (570) 779-5122. FHAS provides a communication team specific to IDR from 8:00 am to 5:00 pm EST. Further, if you are not able to reach a team member by phone, leave a voicemail and someone from our team will get back to you in a timely manner.