Pillar · Dispute Process

Patient-Provider Dispute Resolution: Filing, Timeline, and What the Reviewer Actually Decides

September 2026 10 min read cashmedical.co

If you are uninsured or self-pay, you received a Good Faith Estimate before your care, and the final bill from any single provider or facility exceeds that estimate by $400 or more, you have the right to initiate a federal dispute. The process is called Patient-Provider Dispute Resolution (PPDR), and it has been available since January 1, 2022 under the No Surprises Act. This article walks through every step, from filing to decision.

Who qualifies

You qualify if all three of these are true:

The $400 threshold applies per provider or facility, not to the total bill. If the hospital's bill exceeds the hospital's portion of the GFE by $400, you can dispute that. If the surgeon's bill exceeds the surgeon's portion by $400, you can dispute that separately. Each is a separate dispute.

The process, step by step

StepDeadlineWhat Happens
1. Receive the billDay 0You receive a bill that exceeds your GFE by $400+ from a single provider or facility
2. Initiate disputeWithin 120 calendar days of the billSubmit the CMS initiation form online, with a copy of your GFE and the bill
3. Pay $25 feeWith initiationNon-refundable administrative fee required to process the dispute
4. Provider response~30 days after notificationProvider submits documentation to the Selected Dispute Resolution (SDR) entity
5. Negotiation windowDuring review periodYou and the provider can settle directly at any time; notify the SDR entity if you do
6. SDR entity decisionWithin 30 business days of receiving complete submissionsIndependent reviewer determines the payment amount. Decision is binding.

What the reviewer decides

The Selected Dispute Resolution entity is an independent, HHS-certified reviewer. The reviewer determines the amount you owe for the billed services. The decision is binding on both you and the provider. There is no appeal.

The reviewer considers:

The reviewer does not consider what insurance would have paid, what Medicare pays, or what other patients were charged. The comparison is strictly between the GFE and the final bill.

Practical tips

Save your GFE. The entire dispute process depends on having a copy of the Good Faith Estimate you received before care. If you did not receive one, you may not have standing to dispute under this specific process (though other options exist, including state-level protections and direct negotiation).

File promptly. The 120-day window starts from the date on the bill, not the date you opened the envelope. If you dispute on day 121, the process is closed.

The $25 fee is real but small. It is non-refundable regardless of outcome. Think of it as the filing fee for small claims court. If the dispute involves a $2,000 discrepancy, the fee is trivial relative to the potential savings.

Settlement is always an option. Many providers will negotiate directly once they receive notice that a dispute has been filed, because the dispute process costs them administrative time and uncertainty. The threat of a binding third-party decision is itself leverage.

What the PPDR does not cover: Ground ambulance bills, bills from providers in states that have opted to enforce their own dispute process in lieu of the federal one, and bills where no GFE was issued. If you did not receive a GFE and you should have, the provider may be in violation of the No Surprises Act, which is a separate enforcement matter you can report to CMS or your state regulator.

How to file

The initiation form is available on the CMS No Surprises Act website. You need: a completed Patient-Provider Dispute Resolution Initiation Form, a copy of your Good Faith Estimate, the bill or Explanation of Benefits showing the charges that exceed the estimate, and the $25 administrative fee. CMS routes the dispute to an SDR entity in your region.

Related on this site

Good Faith Estimate explained covers the pre-care estimate that serves as the baseline for any dispute.

The ground ambulance gap covers the services this dispute process does not reach.

Elsewhere in the network

The Ledger on requestmedicalquote.com covers the intake and quote-request process from the patient side.

Dispute a bill above Good Faith Estimate on saveonsurgery.co covers the dispute process from a savings-tactics angle.