The Departments of Health and Human Services, Labor, and the Treasury finalized a new Federal Independent Dispute Resolution (IDR) administrative fee of $15 per party per dispute, down from $115 per party per dispute, for disputes initiated on or after June 11, 2026 (91 FR 33949 at 1517, 1586; 26 CFR 54.9816-8(d)(2)(ii)(B), 29 CFR 2590.716-8(d)(2)(ii)(B), and 45 CFR 149.510(d)(2)(ii)(B)). This page states what the fee is, who owes it, when it is due, what portion is refunded, and walks through arithmetic on when a small dispute now makes economic sense to file. It gives no opinion on whether any dispute would be won.
The administrative fee is owed by both the initiating party and the non-initiating party, regardless of the dispute's eventual eligibility or outcome (45 CFR 149.510(d)(2)(i)). The Departments considered charging non-initiating parties less for disputes later found ineligible, and declined: the rule keeps one flat $15-per-party fee "for all disputes," finding that a uniform fee "better accounts for dispute initiation costs that attach to every dispute, regardless of eligibility" (91 FR 33949 at 2228). The obligation to pay attaches at final selection of the certified IDR entity, and the current timing of collection is unchanged: certified IDR entities may invoice at selection and collect no later than the time of offer submission (91 FR 33949 at 1614).
The fee is not a policy lever set by preference; it is a calculated cost-recovery figure. The Departments' own methodology divides the Departments' estimated annual Federal IDR process expenditures by the estimated annual number of administrative fees paid, using data from May 2025 through April 2026: $119.4 million in expenditures divided by an estimated 6.9 million administrative fees paid, producing $15 per party per dispute (91 FR 33949 at 1517, 2110). The Departments had proposed $150 per party per dispute in 2023 using a different, not-finalized methodology; commenters argued that figure would price out small and rural providers, and the Departments agreed the $15 figure "significantly" mitigates that concern (91 FR 33949 at 1587, 1591, 1721).
The administrative fee itself is non-refundable -- it is "due to the Departments... regardless of dispute eligibility" (91 FR 33949 at 1614). What the $15 change does not touch is the certified IDR entity fee, a separate charge each party pays to the entity that actually reviews and decides the dispute, and which the entity is required to refund to the party whose offer is selected (or split evenly if each side's offer is selected on an equal number of batched items) within 30 business days of the determination (45 CFR 149.510(d)(1)(iii)). If a dispute is found ineligible, or the parties settle or withdraw before an eligibility determination, the certified IDR entity must return the entirety of each party's certified IDR entity fee within 30 business days (45 CFR 149.510(d)(1)(v)). Confusing the two fees is common: the $15 figure this page describes is never refunded; the separate entity fee often is.
The Departments' own estimate of the effect: they project the lower fee will increase annual dispute volume by roughly 30 percent, and separately estimate that other changes in the same rule (enhanced disclosure, portal-based negotiation) will cut the number of ineligible disputes filed by 50 to 75 percent -- a projected saving to parties of $8,775,000 to $13,162,500 per year in administrative fees alone that would otherwise have been paid on disputes that turn out ineligible (91 FR 33949 at 2056).
Put in per-dispute terms: at the prior $115-per-party fee, the two parties to a single dispute together paid $230 in administrative fees before either party's certified IDR entity fee was even collected. At $15 per party, the same two parties pay $30 together -- a $200 reduction in the fixed cost of finding out whether a dispute is eligible at all. For a provider weighing whether a single low-dollar claim is worth pursuing, that $200 difference sits entirely on the cost side of the ledger; it says nothing about the claim's eventual outcome, only that the price of finding out has dropped by roughly 87 percent. A claim whose disputed value was too close to the old $115 administrative fee to justify filing may clear that bar today purely because the fee fell, before any batching or entity-fee consideration is added. Batching multiple qualified items into a single dispute (see our companion guide on the 2026 batching rules) changes this arithmetic further by spreading one administrative fee obligation, per party, across more than one item.
This page states no view on whether the No Surprises Act's other conditions -- open negotiation, timely initiation, the definition of a qualified IDR item or service -- are met for any specific claim, and gives no advice on what offer to submit or what amount to expect. Eligibility is decided case by case by the certified IDR entity assigned to the dispute (45 CFR 149.510(c)(2)).
Trilatic is preparing an application to become a certified Federal IDR entity and is not accepting disputes. This guide states no outcome and gives no advice on offers or amounts. It is not legal advice. Published 2026-09-13; last checked against primary sources on 2026-09-13.
A free, stateless eligibility pre-screen is available at /prescreen. Check your dispute before you pay the fees: /precheck