Methodology version: nsa_idr_passport_v1 · Effective: 2026-09-06 (v1, pre-certification) · Entity: Ripplarity Inc, a Delaware corporation, doing business as Trilatic. It is preparing an application for certification as a Federal Independent Dispute Resolution (IDR) entity under 45 CFR 149.510; on certification it will decide out-of-network payment disputes as described below. This page describes, in plain language, the commitments every determination is held to. It is the standard we expect the Departments, the parties to a dispute, and any member of the public to check us against.
For every dispute, we consider information in the order 45 CFR 149.510(c)(4)(iii) sets out:
We never select an offer by splitting the difference or by any formula not tied to these factors. The written decision states which factors were relied on and why, and which factors were raised but excluded, with reasons.
By law (149.510(c)(4)(v)), three categories are excluded, no matter who submits them or how they're framed: usual and customary charges (including rates expressed as a percentage of them); billed charges (what would have been billed absent balance-billing protections); and public payor rates (Medicare, Medicaid, CHIP, TRICARE, VA, or state 1115A rates). Every submission is screened for these before any reviewer weighs it, and flagged material is excluded from the record.
We accept selection by either party to a dispute — the initiating party naming us directly, or the non-initiating party proposing us after objecting to the initiator's first choice — by joint agreement of both parties, or by random assignment from the Departments. We publish our determination outcomes broken out by which of these routes led to our selection, and we maintain no commercial, referral, or fee arrangement with any party, payer, provider group, or filer that could influence which route selects us.
Before we look at any dollar amount, every dispute is checked against each eligibility ground the rule sets out: NSA applicability, State law, Open negotiation, Initiation window, Batching, Cooling-off, Duplicate, Wrong party, and Missing information. Where the rule allows a cure (a mis-named party, a missing field), the parties are told and given the 5-business-day cure period; where it does not, we notify both parties and the Departments and stop there.
Eligibility, together with our conflict-of-interest check (below), is decided within 5 business days of final selection.
Batching does not change the substantive test — each line item in a batch is weighed under the same considerations as a single dispute. What batching changes is administrative handling: one fee, one timeline, for the items that qualify. We apply the batching conditions of 45 CFR 149.510(c)(4)(i) as amended by the June 2026 IDR Operations final rule (91 FR 33949): the 50-item cap, the 30-business-day service-date window, and the permitted batching bases. An item that does not qualify is excluded from the batch; it does not sink the batch, and the parties are notified inside the same 5-business-day eligibility window as every other eligibility decision.
Every determination is assigned to a case team drawn from our credentialed roster. Before we ever touch the substance of a case, every case-team member is screened for the conflicts 45 CFR 149.510(c)(1)(ii)(D) and (c)(5) describe — employment or contract with either party, close family relationships with either party's officers, and material financial relationships — over the preceding 12 months. We file an attestation of no conflict — or a decline, if one exists — within 3 business days of selection, as the rule requires. A decline sends the dispute back for reselection; it does not proceed with us.
If you believe we have a conflict. Either party may object to a named case-team member, with reasons, at any point before a determination issues; contact objections@trilatic.com. A late- discovered conflict is handled the same as one caught at selection — a decline and reassignment, never a determination issued around it. The 3-business-day attestation itself (clean or a decline) is available to both parties on request.
If one party submits no offer or no supporting information by the deadline, we issue a default determination based on the other party's timely, admissible submission and the QPA. A default determination goes through the same human sign-off as every other case — it is shorter because there is less to weigh, not because it gets less scrutiny.
Role of software (summary). Every submission passes a prohibited-factor filter before any reviewer weighs it, and flagged material is excluded from the record. The offer selected is always the one nearest the credible value on the record under 149.510(c)(4). We never split the difference, and we never apply a formula that is not tied to the factors that provision permits. In practice that means: where neither party submits credible information justifying a departure from the qualifying payment amount, the offer nearest that amount is the one selected, because the QPA is the anchor the rule requires us to consider first; where a party does submit such information, the offer nearest the value that evidence supports is selected instead, and the written decision says which factor carried the weight. The reviewer may reach a different conclusion from the draft in either direction, and any override is recorded with a written reason. Any confidence stated in a draft is a probability, never a certainty, and a model never issues a determination. We do not communicate with any party about a pending dispute outside the official portal record, and the entity answers any inquiry from the Departments about this software's role in full.
Our case-management software supports intake, eligibility screening, prohibited-factor screening, and the preparation of a draft written decision from the admissible record. No determination is ever issued without a credentialed human — an attorney or senior reviewer holding the required arbitration credentials — independently reviewing and signing it. That reviewer checks the offer selected, confirms the rationale cites only admissible considerations and does not double-count against the QPA, and confirms no prohibited factor appears anywhere in the reasoning. The reviewer may accept, edit, or override the draft. The software drafts; a licensed human decides.
At issuance, every determination is cryptographically sealed so that it cannot be altered without detection. Anyone — either party, the Departments, or the public — can check that a determination's content matches what we issued at https://trilatic.com/verify/{determination-id}. Verification never exposes protected health information; it confirms integrity, not content.
Every quarter, we publish a public record covering: number of determinations issued; median and p90 turnaround time in business days; the share of disputes resolved by determination versus settlement/withdrawal; the share that were defaults; and, once we have enough volume, our own calibration and how often a determination was later challenged or reversed on judicial review.
k-floor suppression rule: any cell in the published record representing fewer than 11 determinations is suppressed or aggregated with an adjacent cell, so no combination of filters can be used to identify an individual dispute, provider, or plan. Protecting against re-identification takes priority over granularity.
This page carries a version string (nsa_idr_passport_v1). Any change to the considerations we weigh, the eligibility checks we run, the conflict-screening process, or the software's role is released as a new version with a dated changelog at https://trilatic.com/methodology, and applies only to determinations selected on or after the new version's effective date. Determinations already issued are never re-evaluated under a later version.
If you believe a determination we issued reflects a conflict of interest, considered a prohibited factor, or otherwise departed from this methodology, contact compliance@trilatic.com. Concerns involving a possible conflict of interest are also reportable directly to the Departments at FederalIDRQuestions@cms.hhs.gov, or through the public petition process under 45 CFR 149.510(e)(5). We log every concern received, our investigation, and its outcome, and retain that record for six years alongside the determination itself.