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Policy Updates

10-05-23 Update: TMA III & IV Ruling – How To Proceed

By October 5, 2023March 18th, 2024No Comments

FHAS wanted to clear up some confusion:

As we mentioned last week, there were issues with NOOF links. Today, 10/5/2023 CMS sent the following communication:


After the 9/20/2023 evening release turning on the Notice of Offer (NOOF) functionality in the Federal IDR Portal, a small number of disputing parties reported that they were not able to submit their completed notice of offer web form due to an inactive submit button. We have confirmed that their reported web form submission issue is not system wide and is isolated to a smaller subset of web form users.

To resolve the reported submission issue for those parties, the IDR IT Development Team will be republishing the NOOF web form for impacted parties on the evening of Thursday, October 5. The NOOF due date of impacted dispute records will be extended 10 business days, to 10/20/2023, in the portal.

Please note, for impacted parties. CMS pre-determined which disputes were impacted and sent a list to each entity of who would receive the extension from CMS. Before sending this email – all parties involved in these disputes were notified of their granted extension. If FHAS did not reach out with the Subject: “Extension Granted for Impacted Parties of Inactive Submit Button,” then you did not receive an extension for your dispute.

FHAS will grant any remaining needed extensions by request if you did not receive one by CMS.

Email us at with dispute numbers and the reason for the extension request. Before requesting ensure the dispute is in an active status – as well as single/ bundled.

The entities are expected to meet with CMS tomorrow, so another update will be forthcoming.

There are no other updates at this time.

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