Compliance
No Surprises Act: What Employers and Patients Need to Know About the 2026 Qualifying Payment Amounts
Upcoming increases in the Qualifying Payment Amounts under the No Surprises Act will alter patient cost sharing and provider reimbursement. This article guides both employers and individuals through the changes and how to prepare.
By NomadicTax Research Team • 5-8 min read • November 22, 2025
## Overview of the No Surprises Act QPA Changes
The IRS has issued **Notice 2025-65**, which sets forth the **percentage increase** for calculating **Qualifying Payment Amounts (QPAs)** for items and services furnished in 2026, pursuant to the rules under IRC sections 9816-9817, ERISA, and the Public Health Service Act.([irs.gov](https://www.irs.gov/irb/2025-47_IRB?utm_source=openai))
Key points:
- The percentage increase for 2025-2026 is **1.0265311701**, meaning QPAs increase by ~2.65%.([irs.gov](https://www.irs.gov/irb/2025-47_IRB?utm_source=openai))
- Plans and issuers may round resulting QPAs to the nearest dollar.
- The notice also provides **cumulative percentage increases** if the base year of QPA origination is earlier (e.g., 2019, 2021, etc.).([irs.gov](https://www.irs.gov/irb/2025-47_IRB?utm_source=openai))
- Effective **January 1, 2026**.([irs.gov](https://www.irs.gov/irb/2025-47_IRB?utm_source=openai))
## Who is Impacted and How
### Patients / Covered Individuals
- **Higher cost-sharing ceilings**: When insured patients receive surprise bills that fall under QPA rules, the provider/in-network amount they’re compared against will be higher—this could lead to higher out-of-pocket liability in some scenarios.
- **Greater transparency importance**: Patients should understand how estimates are calculated, especially in emergencies or with out-of-network providers.
### Insurance Plans & Issuers
- Must use updated QPA values in crafting contracts, notices, and in dispute resolution for surprise-billing claims. A 2.65% increase may seem small, but in high cost states or for specialty services, this can shift payment responsibility significantly.
- Critical for budgeting: health plan finance teams should update model assumptions to reflect these new baseline increases to avoid underfunding.
## Example: How the Increase Works
Imagine a medical service that in 2025 has a QPA of **$1,000**. In 2026, it increases by 2.6531% to **$1,026.53**. Depending on rounding rules, the plan/issuer may treat this as **$1,027**. If the provider bills $1,500 and the patient’s cost sharing is based on the QPA, the 2026 obligation might increase moderately, especially for high-deductible plans or coinsurance calculations.
## Compliance Tips for Employers & Insurers
- **Audit your billing contracts**: Ensure agreements with providers and third parties reflect the new QPA rules and incorporate new increase factors.
- **Provider network negotiation**: With a new baseline, negotiate out-of-network reimbursement based on updated QPAs to preserve provider-network stability.
- **Train internal operations & billing teams** on the change to avoid miscalculations or miss-submission of claims.
## Actionable Steps for Individuals & Employers Now
1. **Review your plan’s surprise billing policy** to understand how your cost share is affected if you receive a surprise bill.
2. **Insurers**: Update provider fee schedules, paperwork, and disclosure documents to reflect January 1, 2026 changes.
3. **Employers offering coverage**: Communicate to employees that surprise billing protections remain, but cost-sharing may shift slightly due to increased baseline QPAs.
## Conclusion
The No Surprises Act continues to evolve in application—with the 2026 QPA increases being a straightforward but meaningful change. Whether you’re an insurer, employer, or patient, knowing how the change fits into your financial planning or health care decisions will help avoid unwelcome surprises.