Batching vs. bundling: getting it right

Batching is how the federal IDR process achieves economies of scale: multiple qualified items and services resolved in a single dispute, for a single batched entity fee. It is also the eligibility requirement most frequently gotten wrong — and an improper batch does not merely lose a few line items, it can render the dispute ineligible after your initiation window has already burned. This guide covers the difference between batching and bundling, the criteria in effect today, and the significant changes arriving under the 2026 IDR Operations final rule.

Batching and bundling are not the same thing

A batched dispute is multiple separately billed items and services submitted together in one IDR initiation because they satisfy the federal batching criteria. A bundled payment arrangement is different: it is a single payment covering multiple items and services under the terms of the plan or contract — and for IDR purposes, a bundled arrangement is generally treated as a single item or service, not as a batch of its components. Attempting to "batch" the components of a bundled arrangement, or conversely treating separately billed services as if they were one bundled item, are both recurring sources of eligibility failures.

The batching criteria in effect today

Under the rules currently in effect, batched disputes must involve the same parties — the same provider, group, or facility on one side and the same group health plan or issuer on the other — and the same or similar items and services, generally meaning those billed under the same or comparable service codes. The items must also either have been furnished within the same 30-business-day period, or have open negotiation periods that end during the same 90-calendar-day cooling-off period following a prior determination between the parties. There is currently no cap on the number of line items in a batch.

What changes under the 2026 Operations final rule

For disputes with open negotiation periods beginning on or after approximately November 1, 2026, two things change. First, batched disputes are capped at 50 line items. Second, the "same or similar" test is replaced by revised similar-condition criteria: items and services from a single patient encounter on the same claim form; items billed under the same or comparable service code across multiple patients; or anesthesiology, radiology, pathology, or laboratory items within the same Category I CPT code section. High-volume filers who currently rely on large mixed batches should model their filing strategy against these criteria now, because a batch that is routine today may need to be split into several disputes — each with its own entity fee — after the transition.

The errors we see most often

Mixing plans or issuers on the non-initiating side; stretching "similar" across service codes that are not comparable; combining items furnished outside a single qualifying window; batching the components of a bundled payment arrangement; and — increasingly relevant — building batches that will exceed the 50-line cap for open negotiation periods that begin after the transition date. Each of these surfaces during the certified IDR entity's eligibility review, when it is too late to repair the initiation.

How batching interacts with fees

medlitix's published fee schedule prices batched determinations at a flat fee covering up to 25 line items, with a fixed fee for each additional increment of 25. Because the fee tiers are transparent, parties can price a batch before filing — and weigh whether splitting or consolidating disputes makes economic sense under the criteria that apply to their initiation date. Our guide to determining dispute eligibility covers the other five tests every dispute must pass, and the IDR deadline calculator computes the windows that batching decisions depend on.

This guide is general information, not legal advice. Batching criteria have been revised across successive rulemakings and litigation; confirm the rules applicable to your dispute's dates at cms.gov/nosurprises before filing.