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IDR Temporary Extension Policy
Effective 12/15/2023


Effective December 15, 2023, the U.S. Departments of Health and Human Services, Labor, and the Treasury (the Departments) announced the following extensions for the Independent Dispute Review Entity (IDRE) process under the No Surprises Act (NSA):

     Through March 14, 2024, the Departments have authorized extensions to certain IDR timelines.

     1. Disputing parties may request and certified IDR entities may grant additional time to submit a Notice of Offer;

     2. Certified IDR entities may allow disputing parties additional time to respond to requests for additional information; and

     3. The certified IDR entity selection and reselection process will be extended to 10 business days, rather than 3 business days.

Source: Overview of rules & fact sheets | CMS

The Departments have stated IDREs have flexibility to determine how Notice of Offer extensions are granted. FHAS understands that parties require more time to properly submit offers to FHAS based upon the large number of cases due to case filings resulting from the reopening of the IDRE portal.

FHAS Extension Policy

1. FHAS requires party extension requests to be submitted prior to the notice of offer due date.


2. If a party requests an extension after the due date, the extension will not be granted. The dispute will be processed based upon the documentation submitted by the parties prior to the due date.


3. If a party cannot meet the granted extension timeline, a party may request a second extension.


Please note: IDREs are restricted by the Departments to extend offer deadlines in 10-day increments.

How to Request an Extension

1. Send an email to with Extension Request in the subject line.

2. Include the following information in the body of the email:

     a. Dispute numbers requiring extension and their corresponding Notice of Offer Due Date.

     b. The reason for extension (e.g. overwhelming number of disputes, limited resources)

Questions: Please email with the subject line "Extension Inquiries"

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