Process

Batching under the 2026 rule: 50 items, three ways to group

The 2026 federal IDR operations rule caps batched disputes at 50 line items and allows three ways to group them. Here is how each one works.

5 min readRevise Medical

The Departments finalized a limit of 50 line items per batched dispute. They estimate the cap covers 99 percent of batched disputes filed so far.3

Three ways to group

  • One patient encounter: items for one patient on the same or consecutive dates of service, billed on the same claim form.
  • Same service code: items for one or more patients billed under the same service code, or a comparable code in another code system.
  • Same CPT section: anesthesiology, radiology, pathology and laboratory items under the same Category I CPT code section, as the Departments’ guidance specifies.4

When it applies

The new batching definition applies to disputes whose open negotiation period begins 90 days after the rule’s effective date. Until then the earlier batching rules govern. Check the date your open negotiation started, not the date you file.4

What good batching looks like

A batch shares an IDRE, a pair of offers and a decision. Mixing strong and weak items drags the strong ones down. We build batches around payer, plan type and code family, and we keep claims with unusual QPAs out of batches so they can be argued on their own.

Summaries of public rules and filings. Not legal advice.

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Sources

  1. 3Federal Independent Dispute Resolution Operations, final rules, Federal Register doc. 2026-11140, June 4, 2026: batched disputes limited to 50 line items; most process changes apply to open negotiations that begin 90 days after the Departments announce the supporting functionality. Source
  2. 4CMS fact sheet, Federal Independent Dispute Resolution Operations final rule (2026): open negotiation through the federal IDR portal, response by business day 15, eligibility decided within 5 business days of IDRE selection, three batching options. Source