Lexology March 10, 2025
The U.S. Department of Labor (DOL), U.S. Department of Health and Human Services (HHS), and the Internal Revenue Service (IRS) have issued FAQs About Consolidated Appropriations Act, 2021 Implementation Part 69. The FAQs provide guidance on the calculation of the qualifying payment amount (QPA) used in the independent dispute resolution (IDR) process under the No Surprises Act. The FAQs also extended enforcement relief a second time for plans, insurers, and parties to IDR disputes. Separately, the IRS issued a notice containing the indexing factor for QPA calculations for the 2025 calendar year.
Plans and insurers should take note of this guidance as they calculate QPAs under the complex patchwork of regulations, guidance, and court decisions.
Guidance on QPA Calculations
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