No Surprises Act IDR information collection submitted to OMB
The Department of Labor's Employee Benefits Security Administration submitted its No Surprises Act IDR Process information collection to the Office of Management and Budget on November 26, 2025. The notice, document 2025-21113, estimates 2,755,048 responses a year and invited comments through December 26, 2025.
Written by Salman Saeed, CEO and Co-Founder · Reviewed by a Certified Medical Coder · 
In short: this is a Paperwork Reduction Act notice, not a new rule. It asks OMB to renew approval for the paperwork that supports the federal IDR process under OMB Control Number 1210-0169, and it adds no new filing duty for providers.
What notice was published on November 26, 2025?
The Department of Labor published "Agency Information Collection Activities; Submission for OMB Review; Comment Request; No Surprises Act: IDR Process" in the Federal Register on November 26, 2025, as document 2025-21113 at 90 FR 54399. The notice is signed by a DOL Senior Paperwork Reduction Act Analyst, not by CMS.
Under the Paperwork Reduction Act (PRA), a federal agency generally cannot conduct a collection of information unless OMB approves it and displays a valid control number. This notice is DOL's request, as the Employee Benefits Security Administration sponsor, for OMB to review the collection. The notice describes federal IDR as the process that nonparticipating providers or facilities and group health plans and issuers may use after an unsuccessful open negotiation period.
What does the notice estimate?
| Item | Figure in the notice |
|---|---|
| Collection title | No Surprises Act: IDR Process |
| OMB Control Number | 1210-0169 |
| Agency | DOL-EBSA |
| Affected public | Private sector |
| Total estimated number of respondents | 2,000,012 |
| Total estimated number of responses | 2,755,048 |
| Total estimated annual time burden | 1,691,251 hours |
| Total estimated annual other costs burden | $58,518,032 |
| Authorization requested | Three years |
| Comment deadline to OMB | December 26, 2025 |
The notice does not list the individual forms. For substantive detail on the collection it refers readers to the related notice published on January 6, 2025 at 90 FR 671.
Where does the request stand now?
The OMB control number history on reginfo.gov shows ICR reference 202508-1210-009 for 1210-0169, an extension without change of a currently approved collection, received by OIRA on 11/26/2025 and concluded 06/04/2026 as approved without change.
The same history lists a later revision request, 202606-1210-003, received 06/09/2026 with no conclusion date shown on October 26, 2026. A revision request is how an agency adds changes to a collection already in use, so watch reginfo.gov for it.
Who does this affect?
The collection supports the federal IDR process that hospitals, emergency departments, physician groups, facilities and air ambulance providers use against plans and issuers. The notice lists the affected public as the private sector.
A PRA notice does not change what you file in a dispute. The filing deadlines and fees come from 45 CFR 149.510, and the rule changes that took effect in 2026 are covered in our rule publication post.
What should billing teams do now?
- Do nothing for this notice: its comment period closed on December 26, 2025 and the extension is shown as approved.
- Keep filing through the Federal IDR portal or IDR Gateway as CMS instructs, and follow the dates on the CMS notices page.
- Watch reginfo.gov for control number 1210-0169 if your team wants to read any revised forms before they take effect.
- Use the federal IDR process page for the step by step filing sequence.
What is still open?
The pending revision request and any new forms are the open items. The notice's own description of the Consolidated Appropriations Act provisions is background. For rule changes, see the IDR operations rule page, and for common questions see the No Surprises Act FAQ. If you want help with disputes, book a call.
- Agency Information Collection Activities; Submission for OMB Review; Comment Request; No Surprises Act: IDR Process, 90 FR 54399 (November 26, 2025) · Federal Register (govinfo)
- OMB Control Number History, 1210-0169 · Office of Management and Budget (reginfo.gov)
We check every rule, code and deadline against the official source. See our editorial policy.
Common questions
Straight answers from the team that does the work.
Ask a billing lead directly. A 20-minute call, Monday to Friday, 9am to 5pm Eastern.
01Who published the No Surprises Act IDR information collection notice?
The Department of Labor published it, not CMS. It is a Paperwork Reduction Act notice from the Employee Benefits Security Administration, document 2025-21113, published November 26, 2025 at 90 FR 54399, asking OMB to review the collection titled No Surprises Act: IDR Process.
02What is OMB Control Number 1210-0169?
It is the OMB control number for DOL-EBSA's No Surprises Act: IDR Process information collection. The November 26, 2025 notice asked OMB to authorize it for three years. Reginfo.gov shows an extension request received November 26, 2025 and approved without change on June 4, 2026.
03How much paperwork burden does the notice estimate?
The notice estimates 2,000,012 respondents, 2,755,048 responses, 1,691,251 hours of annual time burden and $58,518,032 in annual other costs. It lists the affected public as the private sector, and it asks OMB to authorize the collection for three years. Comments went to OMB through reginfo.gov.
04Did this notice change what providers must file in federal IDR?
No. It is a renewal request under the Paperwork Reduction Act, and it creates no new filing duty. Providers still follow 45 CFR 149.510 and the CMS notices page for forms, fees and deadlines in their federal IDR disputes, and this notice does not alter any of those.
Talk to a billing lead.
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