Compliance News | September 18, 2026
The Federal IDR Team recently announced that prospective users of the independent dispute resolution (IDR) Gateway, a secure online platform for managing IDR disputes, can now register for an IDR Gateway account. Additionally, the team released several guidance documents to support the transition to the IDR Gateway.
Account creation for the IDR Gateway is now open. The IDR Team, which includes the Departments of Labor, Health and Human Services, and the Treasury, the agencies responsible for implementing the IDR operations final rule (see background on the final rule), announced that all prospective IDR Gateway users could begin creating accounts beginning September 15, 2026.
To sign up for the IDR Gateway, users should visit the IDR Gateway Access page and either create an account and complete identity verification or sign in using existing credentials, such as for Centers for Medicare & Medicaid Services Identity Management (CMS IDM) or Login.gov. The IDR Gateway is expected to launch its initial IDR process functionality in November 2026, with additional functionality implemented on a rolling basis.
The Federal IDR Team reiterated that plan sponsors that rely on a third-party administrator (TPA) or other service provider to manage IDR disputes do not need to create their own IDR Gateway account. Because the IDR Gateway does not include functionality to link affiliated organizations, entities named in disputes that are not involved in the day-to-day administration of those disputes should not register for an account. Instead, plan sponsors should ensure that their TPA or other service provider has registered for and maintains an active IDR Gateway account.
Alongside the launch of IDR Gateway account creation, the Federal IDR Team released several instructional resources, including:
Note that the Federal IDR Team indicated that while the IDR process transitions to the IDR Gateway, parties can continue to submit web forms without signing in to the IDR Gateway. The web forms will no longer be available outside the IDR Gateway after January 15, 2027, except for the “Notice of IDR Initiation – Resubmission” web form. To continue using the Federal IDR process after that, IDR participants must use the IDR Gateway.
Plan sponsors should continue monitoring IDR-related guidance. Sponsors that administer the IDR process directly should review the new instructional resources and create their IDR Gateway account, while those relying on insurers or TPAs should confirm that their vendors are preparing for the transition to the IDR Gateway. Plan sponsors should keep abreast of the new requirements as they become applicable as they will need to comply directly or in coordination with their service provider(s).
Segal will continue to highlight updates on IDR operations as they become available.
The No Surprises Act, which became applicable to most plans in 2022, established the federal IDR process to resolve certain payment disputes between payers and providers involving out-of-network items and services. (See our insights, “New Law Requires Transparency and Prohibits Surprise Billing” and “The No Surprises Act Requires Changes to Your Plan Coverage.”)
On June 4, 2026, the Departments of Labor, Health and Human Services, and the Treasury (collectively, the Departments), along with the Office of Personnel Management, issued a final rule intended to streamline and standardize IDR operations. The final rule also transitions open negotiations and federal IDR activities from single-use web forms to a new IDR Gateway. (For more information about the final rule and background on IDR implementation, see our insight, “Final Rule on Independent Dispute Resolution Operations.”)
The rule became effective August 3, 2026, although some provisions will become applicable only after supporting portal functionality is available and additional guidance is issued. As additional functionality becomes available, the Federal IDR Team will provide notice of its availability and provide the applicable effective date. (For information about prior notices from the Federal IDR Team, see our insights, “IDR Operations Update: A New Gateway and Guidance on Codes” and “Guidance on IDR Gateway Accounts and New Batching Rules.”)
This page is for informational purposes only and does not constitute legal, tax or investment advice. You are encouraged to discuss the issues raised here with your legal, tax and other advisors before determining how the issues apply to your specific situations.