I know many folks have been concerned about the methodology health plans have used to calculate the Qualifying Payment Amounts used for out of network payments under the No Surprises Act. Along with the final rule released this month, a new set of FAQ's were issued, which offered some useful guidance. In general, if contract rates vary by specialty, the median used to calculate the QPA has to be the median for the same specialty. There is also a clear implication that they can't use rates for physicians that never provide the service, so I wouldn't hesitate to argue that contract rates for radiology groups that only bill globally would not be part of the universe used to calculate the median professional component amount.
Discussion starts on page 15 of the attached.
Unfortunately, they are giving the health plans until November 17 to comply.
Dave
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David Smith FACMPE
Executive Director
United Imaging Consultants
Mission KS
(785) 393-8387
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