NOTICE — IDRE-235: Fortuna Arbitration's application for CMS certification as an Independent Dispute Resolution Entity (IDRE-235) is currently pending. Fortuna Arbitration is not yet authorized to adjudicate any CMS IDR cases at this time.

Human Review Process

Every determination passes through a rigorous, multi-layered human review pipeline before issuance. AI assists — humans decide.

Case Workflow Pipeline

Three stages with mandatory quality gates ensure no determination is issued without thorough human oversight at every level.

Stage 1

Case Management & Intake

  • Arbitrus AI generates initial draft determination, including findings of fact, legal analysis, and reasoned conclusions
  • Conflict of interest screening across all parties and staff
  • Jurisdictional routing — federal IDR or applicable state process
  • Case assignment, batching decisions, and administrative workflow management
AI Output Quality Gate
Stage 2 — Tier 1 & Tier 2 Reviewers

Expertise Review

Certified reviewers apply a five-step verification pipeline to every AI-generated output. No determination advances without passing all five steps.

  1. Confirm Jurisdiction — Verify whether the matter is governed by federal IDR or a state process. Cross-check filing requirements and controlling authority. If the AI draft indicates incorrect jurisdiction, annotate the discrepancy and halt review until corrected.
  2. Validate Authorities & Detect Hallucinations — Read every cited case, statute, and regulation. Compare key holdings and quotations to primary sources. Flag and remove any fabricated or outdated citations. Replace with grounded, authoritative support.
  3. Cite-Check & Bluebook Compliance — Apply Bluebook citation rules to every reference. Verify party names, reporters, pincites, and dates. Confirm citation hierarchy. Final product must be publication-ready.
  4. Test Logic & Narrative Coherence — Read the full argument as a single narrative. Confirm each premise logically leads to the next. Identify and resolve non sequiturs, internal inconsistencies, redundancies, and gaps in reasoning.
  5. Approve & Sign — Sign the reviewer attestation block confirming all checks are complete. The determination satisfies Fortuna's human-in-the-loop standard. Release to the next stage only after signature.
Expertise Certification Gate
Stage 3 — Tier 3 Arbitrator Only

Arbitrator Decision

  • Final review by Tier 3 Case Supervisor — the only personnel authorized to issue binding determinations
  • Verification of completeness, groundedness, and factual accuracy
  • Mathematical precision verification of all financial awards and calculations
  • Signed rationale issued with full reasoning (required for CMS IDR cases)
  • Final and binding determination released to all parties
  • All appeals are routed through the CMS IDR appeals process

Hallucination Detection & Quality Control

Every AI output is evaluated through three critical quality lenses before it reaches the arbitrator.

Hallucination Detection

Reviewers verify every cited case, statute, statistic, and procedural step against primary sources. If a statement cannot be traced to a reliable document, it is flagged as a potential hallucination, removed, and replaced with grounded, authoritative support.

Groundedness

Every factual and legal claim must be anchored to a verifiable authority — a contract clause, statute section, reported opinion, or piece of submitted evidence. Grounded writing ensures any reader can follow the reasoning step by step.

Correctness

Reviewers confirm that cited statutes have not been enjoined or amended, that precedent has not been overturned, and that regulations remain in force and unchanged. Outdated or invalid authority is flagged and replaced.

Medical Billing Consistency

CPT and DRG code verification against submitted documentation. Calculation accuracy checks on all payment amounts. Fee schedule compliance review. AI models have known limitations in mathematical computation — human verification is mandatory.

Flagging & Escalation

Any discrepancy in jurisdiction, authority, or reasoning is annotated and triggers an immediate halt in the review process. The determination cannot advance until corrections are made, reviewed, and re-certified. All flagged items are documented in the case record.

The FIAE Certification System

The Fortuna-Insights Adjudication Exam (FIAE) ensures every human reviewer is rigorously trained in legal reasoning, medical billing, citation standards, and CMS IDR rules.

19 hrs
Total Exam Duration
150
Multiple Choice Questions
50%
CMS IDR Rules Coverage
90%+
Tier 3 Pass Threshold
Tier 1 Tier 2 Tier 3
Passing Score 70%+ 70%+ 90%+ plus 4-hr written exam
Role Case Processor Senior Reviewer Arbitrator
Can Issue Opinions No No Yes
Final Decision Authority No No Yes
Exam Components MC + Bluebook Sprint MC + Bluebook Sprint MC + Bluebook + 7hr Essays + 4hr Written

The FIAE is designed to be rigorous by necessity. Fortuna's model depends on efficient, highly trained reviewers who can rapidly evaluate AI outputs for legal sufficiency, factual accuracy, and citation integrity. The exam covers legal reasoning, contract law, jurisdiction, and — most heavily — CMS IDR rules and procedures.

Subject Matter Expert Supervision

Human reviewers are supervised by domain experts across the disciplines essential to IDR determinations.

Healthcare Law

NSA litigation, ERISA, regulatory compliance

AI & Law

Legal AI systems, algorithmic fairness

Arbitration

Labor & commercial

Medical

Board-certified physicians, PM&R, spine

Billing & Coding

Certified adjusters, claims auditing, CPT/DRG

Insurance

Health insurance markets, risk management

Public Health

WHO, health economics, population health