Case Studies

How the No Surprises Act’s QPA Indexing Affects Health Cost Sharing in 2026

Qualifying Payment Amounts for surprise billing protections will adjust for inflation in 2026—here’s how that affects plans, issuers, and your out-of-pocket costs.

By NomadicTax Research Team • 5-8 min read • November 21, 2025

## What is QPA Under the No Surprises Act? The “Qualifying Payment Amount” (QPA) is a benchmark for out-of-network cost sharing in certain surprise medical billing cases, used also by independent dispute resolution entities to set payment rates. It’s based on the **median contracted rate from 2019**, adjusted for inflation over subsequent years. ([irs.gov](https://www.irs.gov/irb/2025-47_IRB?utm_source=openai)) ## New Index Percentage for 2026 Notice 2025-65 announces the factor used to increase QPAs for items or services **furnished during 2026**, applying the year-over-year inflation based on **CPI-U averages** through August 2025. The calculated inflation factor is approximately **1.0265311701**, or a **2.65%** bump over 2025 amounts. ([irs.gov](https://www.irs.gov/irb/2025-47_IRB?utm_source=openai)) ## Implications for Patients and Providers - **Health plans and issuers**: must compute 2026 QPAs based on either the cumulative method from 2019 or an annual increase over 2025. Either approach is allowed but must be used consistently. ([irs.gov](https://www.irs.gov/irb/2025-47_IRB?utm_source=openai)) - **Patients**: cost sharing (i.e., what you pay out-of-network in certain surprise billing cases) may rise slightly due to the inflation adjustment. - **Providers**: the QPA factor influences what health plans will pay under surprise billing disputes, so negotiating or estimating out-of-network payments should keep this increase in mind. ## Practical Steps to Prepare - If your health plan doesn’t already calculate QPAs, establish processes based on 2019 contracted rates and maintain records. - Auditors/regulators could ask for documentation—get clear, dated records of contracted rates and methods used. - Providers working in dispute resolution: update your rate expectations and billing practices according to 2026 QPAs. The new indexing underscores that even small annual inflation rates can meaningfully impact medical cost exposure and reimbursements. **Category:** Case Studies **Author:** NomadicTax Research Team **Read Time:** 5-8 min **Published:** true