Understanding the New IDR Registry – and How It Differs from the IDR Gateway

The next installment of the FHAS Common Questions Series

Our Account Services team members spend their days immersed in the Independent Dispute Resolution (IDR) process and fielding questions from parties. FHAS recently launched a new “Common Questions” series on our blog to share the questions we receive most often, and the answers we’re providing.

Lately, we’ve seen some confusion around the new IDR Registry and the new IDR Gateway, so we’ll address those common questions, here. As a starting place, let’s clarify some basics.

The Gateway is the platform. The Registry is a database inside it.

The IDR Gateway is CMS’s new secure, account-based platform for managing Federal IDR disputes. It replaces the single-use web forms that parties have used since 2022.

Both providers and payers need to register or sign up for a Gateway account. See our earlier post, The IDR Gateway Is Here, for more details on the Gateway roll-out.

The IDR Registry is different. It is a searchable database of payer information that will live inside the Gateway.

Only payers register in the IDR Registry – health insurance issuers, self-insured group health plans and their sponsors, and FEHB carriers. Each payer will carry an IDR registration number, and initiating parties will be able to access this number by referring to a given health plan’s notice of payment or denial.

What is the Registry, exactly?

The Final Rule requires every payer subject to the Federal IDR process to register with the Departments and provide general information about how the process applies to the items and services it covers. Once a payer submits that information, it receives an IDR registration number.

An issuer registers once, covering all of the fully insured individual and group coverage it insures; fully insured employer plans do not register separately. Each self-insured group health plan registers on its own, at the plan level. A third-party administrator (TPA) may complete the registration on a plan’s behalf, but the plan remains responsible for compliance. To enforce accuracy, payers must keep their entries current and confirm them annually; a payer that skips the annual confirmation is treated as unregistered and must re-register.

What information will be in the IDR Registry?

The CMS fact sheet describes the Registry at a high level. The Final Rule itself spells out what each entry must include:

An identifier: the 5-digit HIOS ID, or the plan’s or sponsor’s EIN and plan number, or for FEHB carriers the contract number and plan code.

• The legal business name of the issuer, FEHB carrier, or self-insured plan and, for self-insured plans, the legal business name of the plan sponsor. The Departments kept the sponsor’s name specifically so that self-insured plans using the same TPA can be told apart.
• The registrant type – an issuer, an FEHB carrier, a self-insured ERISA plan, a self- or fully-insured non-federal governmental plan, or a self-insured church plan.
• The state in which an issuer is licensed, or the state(s) in which a self-insured non-federal governmental plan is offered.
• For self-insured plans (including church and non-federal governmental plans) and FEHB carriers, any state(s) whose specified state law the plan has opted into, and whether it is subject to an All-Payer Model Agreement.
• Contact information – telephone and email – for the office that handles open negotiation, and if different, the office that handles IDR initiation. Payers may list more than one contact (for example, different TPAs for different claims) but must also provide a single fallback contact for each purpose.
• Additional information on the applicable out-of-network rate requirements and administrative fee collection will be specified in guidance yet to come.

It’s important to note that any sensitive financial or contractual information will be kept confidential and will not be visible to portal users. Payers will update their entries within 30 calendar days of a change and confirm accuracy annually during the fourth quarter of the year.

What will providers have that they do not have today?

Once the Registry provisions apply, initiating parties can expect:

1. The registration number arrives with the remittance. Payers will include the registration number, along with the legal business name of the plan or issuer and of the plan sponsor, in the initial payment or notice of denial.
2. The registration number unlocks the payer’s registration information. The Departments describe the Registry as searchable and available through the Federal IDR portal to any party preparing to negotiate or initiate a dispute. Parties will be able to look up plan type, state law opt-in status, and the correct contacts for open negotiation and initiation.
3. A clear batching signal. Registration numbers are assigned at the self-insured plan level and, for fully insured coverage, at the issuer level. The Departments set it up that way so that a provider or IDRE can tell whether items and services can be batched together simply by checking whether the registration numbers match.

Registered payers on both sides of every notice. The registration number must appear on the open negotiation notice and response and on the IDR initiation notice and response, and the Departments expect it to be a required field on the offer form. A payer that has not registered will generally be unable to submit an offer until it does.

In short, the Registry gives initiating parties a reliable answer to the two questions that most often derail a dispute before it starts: who is the payer, and does the Federal process apply to this coverage?

When might the Registry be available?

Not right away, and the timeline has several steps. The Final Rule does not set a calendar date for the Registry. Instead, the Registry provisions become applicable 90 business days after the Departments issue guidance announcing that the Gateway functionality supporting the Registry is available, and payers have until the later of that date, or the date they begin offering coverage, to register. The Departments extended that window from the 30 business days originally proposed and noted that the extra time is meant to let payers set up lines of communication across their TPAs and service providers. CMS’s published implementation timeline lists the Registry first among the Gateway-dependent provisions it plans to roll out beginning in spring 2027, ahead of the new open negotiation, initiation, and IDRE selection workflows. Counting forward from a spring 2027 announcement, 90 business days runs roughly four to four and a half months. A reasonable expectation is that payers will be fully registered, and registration numbers will begin appearing on remittances, in the second half of 2027. The Departments have said they will publish updates as each provision is operationalized, and we will share those as they arrive.

In the meantime, one related change lands sooner. Beginning with items and services furnished on or after Jan. 1, 2027, payers must use specified claim adjustment reason codes (CARCs) and remittance advice remark codes (RARCs) to indicate whether a claim is subject to the No Surprises Act and the Federal IDR process. That is a separate requirement from the Registry, but it addresses a neighboring question and arrives first.

Will the IDR Registry help reduce ineligible disputes?

We expect it will, for a specific and meaningful set of cases – and the Departments say so directly. In the Final Rule they write that they “agree that the registry will help providers accurately identify plans, issuers, and FEHB carriers as well as their contact information, reducing the number of ineligible disputes initiated within the Federal IDR process and reducing the number of disputes incorrectly initiated against the wrong plan or issuer.”

A large share of eligibility problems trace back to questions the Registry is designed to answer: whether the dispute names the correct payer, whether the coverage is a self-insured plan or fully insured, whether a state law applies instead of the Federal process, whether items and services can be batched together, and whether the open negotiation notice reached the right contact. When that information is available on the remittance and through the Gateway, an initiating party can resolve those questions before opening negotiation rather than discovering a problem after a dispute has been initiated and fees have been paid.

One caution: Initiating parties should treat the Registry as a strong starting point, not a substitute for their own eligibility review.

The Departments declined to create a safe harbor for disputes initiated in good faith on Registry information that later turns out to be wrong. A dispute that is incorrectly batched or otherwise ineligible cannot proceed, even if the Registry entry was the cause. Instead, the Departments will use their enforcement authority over payers to keep the Registry accurate.

It is worth being clear about what the Registry will not do. It will not determine whether a specific item or service is covered by the No Surprises Act, whether an emergency or non-emergency service qualifies, whether a notice-and-consent exception applies, or whether a dispute was initiated on time. The Departments describe the Registry as one part of a set of changes – alongside the CARC and RARC codes, the new open negotiation notice and response notice, and the revised batching rules – that together are intended to reduce ineligible submissions.

What initiating parties can do now

• Complete Gateway account setup for your organization and users if you have not already; the Registry will only be accessible through the Gateway.
• Watch for the Departments’ guidance announcing that Registry functionality is available. That announcement starts the 90-business-day clock, and registration numbers will begin appearing on remittances after it runs.

What payers (non-initiating parties) can do now

• Payers have more preparation to do because they are the ones who will be registering. The Departments extended the registration window to 90 business days partly to give payers time to set up lines of communication across their TPAs and service providers, so the work can begin now.
• Decide who registers and inventory the plans. An issuer registers once for all the fully insured coverage it insures; each self-insured plan registers separately, at the plan level, with its legal business name, its sponsor’s legal business name, and its EIN and plan number or HIOS ID. A TPA may complete the registration, but the plan remains responsible.
• Settle the contacts and the state law picture. Each entry needs a telephone number and email for open negotiation and, separately, for IDR initiation, plus a single fallback contact for each. Self-insured plans and FEHB carriers will also need to state any specified state law they have opted into.
• Prepare claims systems and a maintenance cycle. The registration number and legal business names will need to appear on every initial payment and notice of denial. Every registrant must confirm its entry each fourth quarter or be treated as unregistered.

FHAS will continue to track the Registry rollout and update this guidance as CMS releases more detail. Meanwhile, if you have questions, don’t hesitate to reach out.