Final Rule Under No Surprises Act Requires IDR Registration

Updated September 2026: On September 15, 2026, CMS opened registration for the new IDR registry (also referred to as the IDR Gateway ). As explained in our unmodified June blog post, included below, this rule requires all plans and issuers that participate in the current Federal IDR process, including group health plans, to register in this system no later than December 14, 2026 (which is 90 days after the IDR Gateway first became available). CMS has indicated it will no longer accept IDR web form submissions outside the IDR Gateway after January 15, 2027.