New Federal IDR Registration Requirements: What Self-Insured Group Health Plans Need to Know

The 2026 Federal Independent Dispute Resolution (“IDR”) rules require self-insured group health plan sponsors to register in the Federal IDR Gateway, the federal system used to administer No Surprises Act payment disputes between plans and out-of-network providers. This requirement is intended to improve the efficiency of the Federal IDR process by establishing a consistent identifier for each group health plan involved in a payment dispute.

A self-insured group health plan will need to register using the plan sponsor’s employer identification number (EIN) as the plan’s unique identifier within the Federal IDR system. The new IDR registration number must then be included on future remittance advice to out-of-network providers. Plan sponsors may rely on a third-party administrator or other service provider to complete the registration and administer the Federal IDR process on the plan’s behalf.

For existing self-insured plans, registration will be required within 90 business days after the federal agencies responsible for administering the No Surprises Act announce that Federal IDR Gateway registration functionality is available. Although the Federal IDR Gateway registration portal is already in place, no action is required at this time because the portal does not yet support the functionality needed to comply with this registration requirement. The Centers for Medicare & Medicaid Services (CMS) currently anticipates making this functionality available in Spring 2027 but has not yet announced the date that will trigger the 90-business-day registration period.

For now, plan sponsors should be aware of the upcoming requirement and consider coordinating with the plan’s third-party administrator or other service provider to discuss responsibility for registration and ongoing administration if they rely on a service provider to handle these disputes.