CMS issued guidance Oct. 29 specifying which radiology services can be batched in No Surprises Act payment disputes, as new batching rules took effect Nov. 1 under the Federal IDR Operations Final Rule. Here are seven things to know:
- The guidance lists 27 radiology CPT code ranges for batching, covering diagnostic imaging, ultrasound, radiologic guidance, mammography, bone and joint studies, radiation oncology and nuclear medicine. Radiology services furnished to one or more patients can be batched only if they fall in the same range. The same ranges, with separate ones for anesthesiology, pathology and laboratory services, apply across specialties.
- CMS’ example is a radiologist who could batch a head CT (CPT 70450) and a sternum X-ray (71120), both in the 70010-71555 head and neck and chest range. The radiologist could not add a lumbar spine CT (72131) or a wrist X-ray (73110) because those fall in different ranges. Services can also be batched if they were furnished to a single patient in one encounter and billed on the same claim form, or if they were billed under the same or comparable codes.
- All batched services must be billed under the same National Provider Identifier or tax ID, be payable by the same plan or issuer, be furnished within the same 30-business-day period and have gone through a 30-business-day open negotiation period that ended within four business days of initiating the dispute.
- For disputes with open negotiation periods beginning on or after Nov. 1, a batch is limited to 50 line items. Modifiers do not count toward the limit, but traditional CPT add-on codes submitted as separate lines do.
- The cooling-off period after a batched payment determination was shortened to 30 business days from 90 calendar days. During that time, the initiating party cannot file another dispute with the same party over the same item or service. The window to initiate a dispute after a batched cooling-off period is four business days, compared with 30 business days after the 90-day period that still applies to single and bundled disputes.
- CMS is moving the federal IDR process to its online IDR Gateway. Starting Nov. 13, organizations with Gateway accounts can submit the notice of IDR initiation, initiation response, certified IDR entity selection and notice of offer forms there. The stand-alone web forms will no longer be available after Jan. 15, 2027, except the resubmission form.
- The final rule also cut the federal administrative fee for disputes to $15 per party from $115, as reported when it was finalized. CMS also said in March it planned to launch the Gateway in the second half of 2026.
