No Surprises Act Deadline Calculator for Open Negotiation and IDR

How Do I Use the NSA Deadline Calculator?

Enter the date the plan or issuer paid the claim or sent the notice of denial, then read the table. Two optional fields let you test a real plan: the date you send the open negotiation notice, and the date you start federal IDR. Leave them blank and the tool assumes the last permitted day for each.

How Is Each Deadline Counted?

Every date below is counted in business days, which skip Saturdays, Sundays and U.S. federal holidays. In the preamble to the June 4, 2026 federal IDR operations final rule, the Departments said that for calculating Federal IDR process timelines, business days do not include Federal holidays and weekends. The calculator uses the 11 legal public holidays in 5 U.S.C. 6103(a), with a Saturday holiday observed on Friday and a Sunday holiday observed on Monday.

The eCFR definitions in 45 CFR 149.30 do not define business day, so that preamble sentence is the official statement. A period that "begins on the day" counts that day as day 1 when it is a business day, and otherwise the next business day.

The date of IDR initiation is the date the Secretary receives the notice of IDR initiation, not the day you prepare it. File early in the window, because a notice that arrives after the fourth business day makes the dispute ineligible.

What Does a Worked Example Look Like?

In this example the notice went out well before its last day, so open negotiation ends earlier than it would have on the last permitted day. Change the notice date and the IDR window moves with it.

Did the 2026 IDR Operations Rule Change These Deadlines?

Not yet for most of them. The final rule, published June 4, 2026 at 91 FR 33900 (document 2026-11140), took effect August 3, 2026, but its changes to open negotiation, initiation, entity selection and the offer and decision timing apply only to disputes with open negotiation periods that begin 90 calendar days after the Departments announce that portal functionality is available. Until each applicability date, the rule says parties must keep following the prior text of 45 CFR 149.510.

CMS's August 7, 2026 implementation timeline says the Departments expect to build those functions in the IDR Gateway in Spring 2027, in the order open negotiation, initiation, entity selection, withdrawals, then extensions. CMS will post a notice, with the applicability date, on its No Surprises Act notices page before each one starts.

When a row changes, this page and the calculator will be updated and the date noted here. The full rule is covered on the 2026 IDR operations rule page.

What Does the Calculator Not Cover?

• State processes, including Texas TDI mediation and other state pathways, which have their own deadlines. See state surprise billing laws.
• Extensions for extenuating circumstances, which can change a date.
• Entity selection by the Secretary: offers and the decision assume the parties jointly pick the entity on the third business day after initiation.
• The payment on an agreed rate (30 business days before November 1, 2026, and 30 calendar days from that date), the administrative and certified IDR entity fees, and batching eligibility. Batching is explained in batching claims.
• Whether the claim qualifies for federal IDR at all, or what to offer. The qualifying payment amount is the usual starting point for an offer.

Treat the output as a working calendar and confirm anything close to a deadline against the rule text. It is not legal advice.

How We Handle NSA Deadlines

Deadline management is one part of our out-of-network work under federal IDR and applicable state pathways: eligibility assessment, open negotiation, dispute submissions, documentation validation and outcome tracking. We track each deadline, keep documentation accurate and pay required fees on time. For the full service, see out-of-network billing and IDR, or book a call and send us a claim to count.

For the steps behind the dates, read open negotiation and the federal IDR process. Filing limits for ordinary claims are in the timely filing calculator.