QPA calculator: index the qualifying payment amount with official IRS factors

Enter a base year rate. Get the indexed QPA for 2025 or 2026, with the exact factor and the IRS notice it comes from.

QPA indexing factor reference table

These are the official consumer price index factors for indexing a qualifying payment amount under the No Surprises Act, exactly as published by the IRS to 10 decimal places. The combined factor is what you multiply a base year median contracted rate by to get the QPA for items and services furnished in 2026.

The full series, the compounding arithmetic, and one worked example per base year are on the complete factor table page.

How the QPA is calculated

The methodology lives in 45 CFR 149.140 and parallel Labor and Treasury rules. The plan, not the provider, runs this calculation. The short version:

Median contracted rate. The plan lists every contracted rate it had on January 31, 2019 for the same or similar item or service, sorts them, and takes the middle value. With an even count, it averages the two middle rates. Each contract counts once, no matter how many providers bill under it, and two separate contracts count twice even when the rate is identical. Risk sharing, bonus, penalty, and other incentive-based or retrospective payments are excluded.

Segmentation. Medians are calculated separately by insurance market: individual, small group, large group, and self-insured. They are also split by geographic region. The default regions are one region for each metropolitan statistical area in a state plus one region for the rest of the state. A plan with fewer than three contracted rates in a region widens to Census division regions. Where rates vary by provider specialty, the median is calculated per specialty.

Indexing. The 2019 median is carried forward by the CPI-U factors on this page. Each year's factor is the average CPI-U for the 12 months ending August 31 of the prior year, divided by the same average one year earlier, rounded to 10 decimal places. Plans are permitted to round the final indexed QPA to the nearest whole dollar.

New plans and new services. A plan without sufficient 2019 rate data uses an eligible database, such as a state all-payer claims database or an independent commercial database, to set the rate for the first year the coverage is offered, then indexes from there. That is why the factor tables carry base years of 2021 through 2025 alongside 2019. New service codes borrow the QPA of a comparable existing code, scaled by the ratio of the two codes' Medicare rates.

The long version, including the self-insured plan rules and the eligible database requirements, is in the plain language methodology guide.

QPA vs what providers actually win

The QPA is the floor of the conversation, not the ceiling. Payers anchor at it: in the federal public use files, the median payer offer is 1.0 times the QPA. Arbitrators do not stay there. Providers win 85.8 percent of federal IDR disputes that reach a decision, and the median award is 4.7 times the qualifying payment amount, based on 3.39 million disputes in the federal public use files.

CMS federal IDR public use files, 2023 through 2025. Explore the full record at idrexplorer.com.

So once you have the indexed QPA from this page, two next steps matter. Estimate what the same claim wins in arbitration, then decide whether filing is worth it. The IDR award calculator at idrcalculator.com estimates your award from the published record. And if you would rather not run the process yourself, Lido IDR has specialists who file and manage your disputes for a flat fee per arbitration, instead of the 15 to 25 percent of the recovery that most vendors charge.