Departments Issue Promised Guidance on Newly Required RARCs:  What Payers and Providers Need to Know 

On July 17, 2026, the Departments of the Treasury, Labor, and Health and Human Services, together with the Office of Personnel Management, issued guidance specifying the remittance advice remark codes (No Surprises Act RARCs) that group health plans and health insurance issuers (payers) must use when communicating with out-of-network providers and facilities relating to claims subject to the No Surprises Act (NSA). 

The guidance implements a requirement established in the Federal Independent Dispute Resolution (IDR) Operations Final Rule, published June 4, 2026, and effective August 3, 2026. Under the final rules, when a payer provides remittance advice — in paper or electronic form — to a care provider or facility that has no direct or indirect contractual relationship with the payer for the item or service, it must use claim adjustment reason codes (CARCs) and RARCs to communicate whether each item or service is subject to the NSA’s surprise billing protections and Federal IDR process. 

The goal of the RARC guidance is straightforward: the remittance advice should tell the receiving provider or facility, at the line-item level, whether a dispute over the payment is eligible for the Federal IDR process. That information determines whether — and on what timeline — the parties can move into open negotiation and, if necessary, Federal IDR. 

To help parties understand and implement the new regulations, FHAS can meet with your team directly to discuss this guidance or other elements of the final rule. Contact your account manager or reach out here.  

The Nine Required Codes 

The guidance specifies nine RARCs, organized by payment circumstance: initial payments, notices of denial of payment, final payments, and items or services outside the NSA’s scope. For details on where the required RARCs must be displayed, see the technical instructions section of guidance provided by the Departments.  

Three Dates to Know 

Three dates matter. The final rules take effect August 3, 2026. The new RARC descriptions become effective in the X12 code set on November 1, 2026. And the requirement to use the codes applies to items and services furnished on or after January 1, 2027. 

What This Means for Payers and Providers 

For plans and issuers, the work between now and January 1, 2027, is operational: mapping each NSA payment circumstance to the correct code, updating claims adjudication and remittance systems, and ensuring accuracy at the line level — the guidance places responsibility on plans and issuers to select the RARC that most accurately applies to each item or service. It is important to note that plans and issuers may continue to use previous RARCs but now must add at least one of the new codes by January 1. 

For providers, facilities, and air ambulance providers, the codes offer an earlier and clearer signal of whether open negotiation and the Federal IDR process are available for a given payment. One important caveat: the plan’s code selection is not the final word on eligibility. Certified IDR entities, such as FHAS, ultimately determine whether a dispute is eligible for the Federal IDR process.  A provider that disagrees with a plan’s use of a code may still initiate the process following the open negotiation period. 

The guidance also addresses noncompliance. If a plan or issuer fails to use the required codes, providers retain the right to initiate open negotiation within 30 days of receiving the initial payment or notice of denial of payment. If that failure leaves a provider without the information needed to initiate the Federal IDR process by the deadline, the provider may request an extension for extenuating circumstances by emailing FederalIDRQuestions@cms.hhs.gov. Compliance concerns may be directed to the No Surprises Help Desk at 1-800-985-3059 or submitted through the CMS billing complaint portal. 

We Are Here to Help 

The Departments have indicated they will continue to assess NSA-related RARCs and may recommend additions or removals through future guidance. As always, FHAS continues to track developments and guidance from the departments as implementation of the final rule continues.  

The IDR process should not feel like a black box. Our client meetings provide clarity, education, and consistent communication—all while maintaining our commitment to impartiality.

If you haven’t booked your account review yet, we encourage you to contact our Account Services team today by emailing us at IDRE@fhas.com or calling 800-664-7177.  Please contact us – we are here to help.