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Appeals court strikes down No Surprises Act QPA formula

08/20/2026
Advocacy Update

A federal appeals court struck down a formula used to calculate the qualifying payment amount (QPA) under the No Surprises Act, the benchmark used in disputes over out-of-network payment rates.

The issue: Physician groups argued that the methodology produced artificially low QPAs by allowing insurers to include rates that were not negotiated and exclude bonus and incentive payments.

The impact: The ruling should allow for more accurate QPA calculations and help ensure physicians are not unfairly disadvantaged during the No Surprises Act arbitration process.