Compliance
Ensuring Compliance Under New PTIN Fee and Employee Plans QPA Changes
IRS has issued new interim regulations lowering the PTIN renewal fee and new indexing rules for group plan health payments. Understand compliance, penalties, and practical next steps.
By NomadicTax Research Team • 5-8 min read • November 20, 2025
## New IRS Policy Highlights
- **PTIN User Fee Reduction:** As of an interim final regulation, the IRS will **reduce the application/renewal fee for a Preparer Tax Identification Number (PTIN)** from **$11 to $10** ([irs.gov](https://www.irs.gov/newsroom/news-releases-for-september-2025?utm_source=openai)).
- **Health Plan Qualifying Payment Amount (QPA) Indexing:** Notice 2025-65 provides *indexing factors* that group health plans and insurers must use for qualifying payment amounts for services provided between **January 1, 2026 and December 31, 2026**. These metrics affect balance billing protections under federal law ([irs.gov](https://www.irs.gov/irb/2025-47_IRB?utm_source=openai)).
## Implications for Tax Preparers and Businesses
- Fat chance of backdating fees now—but those who renew PTIN for the 2026 season should expect new, lower fee structure.
- Preparers must still comply with all PTIN renewal deadlines; missing renewal may mean loss of authority to file returns for clients.
- Employers offering health plans and insurers should review their provider contracts to ensure payment rates align with updated QPA thresholds beginning in 2026.
## Actionable Tips to Stay Compliant
1. **Tax Preparers**
- Verify that your PTIN is active and renew with updated fee.
- Update billing & cost projections if you pass on preparer costs to clients.
2. **Employers & Insurers**
- Review financial projections in your health plan offerings—ensure payments to providers will not be rejected or cause balance billing disputes.
- Update plan documentation to align with QPA indexing; communicate changes to providers and enrollees.
3. **On Documentation & Audit Risk**
- Keep written records of PTIN renewal and new fee payment, including date and amount.
- For health plans, document how QPA was calculated vs payments made—needed for compliance and regulatory defense.
## Practical Example
- **Case:** Maria prepares taxes professionally. She renews her PTIN in November 2025 for the 2026 season. Instead of $11, she pays $10—saving $1, though symbolic, compliance is critical.
- **Case:** XYZ Corporation’s employee health plan sets provider payments for 2026. It normally pays providers above previous years’ QPA benchmarks—but new indexing factors require contract revisions to avoid providers billing more than the qualifying payment amount.
## Potential Pitfalls & how to avoid them
- **Overlooking deadlines:** PTIN renewal opens now; missing deadline may lead to inability to file client returns.
- **Assuming all providers understand QPA:** Insurers and employer health plans must ensure communication and renegotiation of contracts if needed.
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**Takeaway:** Though fee reductions and indexing updates may seem small, noncompliance can lead to penalties, denials, or even compromised provider relationships. Stay proactive—this ensures smooth operation through the 2026 tax year.