CurrentUnitedHealthcarePolicy N/A

No Surprises Act batching rules for IDR payment determinations

This document explains how items and services may be batched and considered jointly by an Independent Dispute Resolution (IDR) entity for a single payment determination under the No Surprises Act, and describes the evidence on the provider remittance advice (PRA) used to determine batching. It affects providers and payers submitting or responding to dispute/negotiation requests.

Policy Summary

PayerUnitedHealthcare

PolicyNo Surprises Act batching rules for IDR payment determinations

Policy CodePolicy N/A

Change TypeNo material changes

Effective DateN/A

Next Review DateN/A

Key ActionAfter Open Negotiation ends, file an IDR through the CMS portal and email a copy of the completed Notice of IDR Initiation to uhg_idr_disputes@uhc.com when prompted for UnitedHealthcare's email.

SourceLink

POLICY UPDATE CHANGES

No material clinical or coverage changes in this revision.

30-business-daybatching period option

90-calendar-daybatching period option

same provider/TIN/NPIrequired provider identifiers for batching

same plan/issuer/grouprequired plan identifiers for batching

same or similar service code

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service coding requirement for batching

Batching rules for single IDR payment determination

Batching criteria

Items and services may be batched and considered jointly by the IDR entity for one payment determination when all the following are true:

ALL of the following

Provided by the same provider, same group of providers, same facility, or same air ambulance provider (billed with the same NPI and/or TIN)
Covered by the same plan or issuer (same issuer/third‑party administrator legal entity name, same group number, and same group name)
Items/services are the same or similar (billed under the same service code or a comparable code in a different procedural code system such as CPT, HCPCS, or DRG, including any modifiers)
Timing
- Furnished within the same 30‑business‑day period
- Furnished within the same 90‑calendar‑day period

Use provider remittance advice (PRA) locations to find required evidence: NPI and/or TIN; issuer/TPA legal entity name, group number and group name; procedure/service codes, modifiers and dates of service.

Service codes, modifiers, and coding rules for batching

Service codes and modifiersmixed

CPT/HCPCS/DRG

Service or procedure code(s) on the PRA used to determine same or similar items/services for batching

Same service code

DefinitionItems/services billed under the same service code or a comparable code in a different procedural code system (e.g., CPT, HCPCS, DRG) qualify as the same or similar; includes applicable modifiers.

ScopeApplied when determining whether multiple items/services may be batched for a single IDR payment determination.

Evidence sourceProcedure/service codes and modifiers on the provider remittance advice (PRA) are used to identify same or comparable codes.

Filing and notification requirements

Prior Authorization

File IDR and notify UnitedHealthcare

After the Open Negotiation period is exhausted, providers may file an Independent Dispute Resolution (IDR) through the CMS portal and must forward a copy of the completed Notice of IDR Initiation form submitted to UnitedHealthcare to uhg_idr_disputes@uhc.com; use this email when CMS prompts for UnitedHealthcare's email.

File the IDR through the Centers for Medicare & Medicaid Services (CMS) portal.
Forward a copy of the completed Notice of IDR Initiation form submitted to UnitedHealthcare to uhg_idr_disputes@uhc.com.
Use uhg_idr_disputes@uhc.com when the CMS IDR form requests an email address for UnitedHealthcare.

Key definitions used in batching rules

Batching

DefinitionThe practice of considering multiple items and services jointly by an IDR entity as part of one payment determination when they meet defined provider, plan, similarity, and timing conditions.

When usedWhen all batching criteria (same provider, same plan/issuer, same or similar items/services, and within the batching period) are met.

OutcomeMay result in a single payment determination for the grouped items/services.

Same provider

DefinitionItems/services provided by the same provider, same group of providers, same facility, or same air ambulance provider billed with the same NPI and/or TIN.

Billing evidenceSame National Provider Identifier (NPI) number and/or tax ID number (TIN) on the PRA.

Policy Summary

PayerUnitedHealthcare

PolicyNo Surprises Act batching rules for IDR payment determinations

Policy CodePolicy N/A

Change TypeNo material changes

Effective DateN/A

Next Review DateN/A

SourceLink

On This Page

Applies toIndividual providers, provider groups, facilities, and air ambulance providers for batching determination.

Same plan or issuer

DefinitionItems/services covered by the same plan or issuer; identified by the combination of issuer/TPA legal entity name, group number, and group name.

Required identifiersIssuer/third-party administrator legal entity name plus group number and group name on the PRA.

PurposeUsed to confirm coverage under the same plan/issuer for batching eligibility.

Same or similar items or services

DefinitionItems/services are the same or similar when billed under the same service code or a comparable code across procedural code systems (e.g., CPT, HCPCS, DRG), including applicable modifiers.

ExamplesExact same CPT code on multiple claims or a CPT code and an equivalent HCPCS/DRG code that represent the same service.

VerificationProcedure/service codes and modifiers on the PRA are used to establish sameness or similarity.

Batching period

DefinitionThe allowable windows for batching are items/services furnished within the same 30-business-day period or within the same 90-calendar-day period.

Options30 business days OR 90 calendar days — items must fall entirely within the selected period to be eligible for batching.

Use in determinationDates of service on the PRA establish whether items/services meet the batching period requirement.