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November 17, 2021: MGMA and leading health organizations urge HHS to revise QPA element of IDR process

Advocacy Letter - November 22, 2021

Health Information Technology

Federal Compliance

November 17, 2021

The Honorable Janet Yellen
U.S. Department of the Treasury
1500 Pennsylvania Avenue, NW
Washington, DC 20220

The Honorable Martin Walsh
U.S. Department of Labor
200 Constitution Avenue, NW Washington, DC 20210

The Honorable Xavier Becerra
Secretary U.S. Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201

Re: Concerns with Interim Final Rule Requirements Related to Surprise Billing: Part II implementing the No Surprises Act (NSA)

Dear Secretaries, Becerra, Walsh, and Yellen:

On behalf of the undersigned organizations representing physicians across the country, we write to urge you to reconsider the requirements in the Interim Final Rule (IFR), entitled “Requirements Related to Surprise Billing; Part II,” 86 Fed. Reg. 55,980 (Oct. 7, 2021), implementing the No Surprises Act (NSA) that directs Independent Dispute Resolution (IDR) entities to consider the qualifying payment amount (QPA) a rebuttable presumptive reasonable payment for out-of-network physicians engaging in the IDR process and, in turn, places a thumb on the scale in favor of health insurers in contract negotiations.

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