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QPA indexing factors 2022 to 2026: the complete IRS table

Under the No Surprises Act, a qualifying payment amount (QPA) starts as the plan's median contracted rate in its base year and is increased each calendar year by a consumer price index factor the IRS publishes to 10 decimal places. The annual factors are 1.0299772040 for 2022 (IRS Notice 2022-11), 1.0768582128 for 2023 (IRS Notice 2023-4), 1.0543149339 for 2024 (IRS Notice 2024-1), 1.0317904930 for 2025 (IRS Notice 2025-12), and 1.0265311701 for 2026 (IRS Notice 2025-65). For the standard January 31, 2019 base year, the combined factor for services furnished in 2026 is 1.2805070065 (IRS Notice 2025-65).

This page reproduces every published factor exactly, shows the compounding arithmetic, and works one example per base year. To apply a factor to your own number, use the QPA calculator.

The annual factors

Each year's factor is the percentage increase in the consumer price index for all urban consumers (CPI-U). The IRS computes it as 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.

Calendar yearAnnual percentage increase factorIRS source notice
20221.0299772040IRS Notice 2022-11
20231.0768582128IRS Notice 2023-4
20241.0543149339IRS Notice 2024-1
20251.0317904930IRS Notice 2025-12
20261.0265311701IRS Notice 2025-65, published in Internal Revenue Bulletin 2025-47
Annual CPI-U percentage increase factors for the No Surprises Act qualifying payment amount, from IRS Notices 2022-11, 2023-4, 2024-1, 2025-12, and 2025-65.

One special case: a QPA with the standard January 31, 2019 base year was first indexed for 2022 in a single step. That step uses the combined 2019 to 2022 adjustment of 1.0648523983 (IRS Notice 2022-11), which folds the 2020, 2021, and 2022 increases into one factor. Base years 2021 and later use only the annual factors above, starting the year after the base year.

Combined factors by base year

The combined factor is the single number you multiply a base year median contracted rate by to get the QPA for a given service year.

Base yearCombined factor to 2026Combined factor to 2025Source for combined factors
2019 (standard)1.28050700651.2474117141IRS Notice 2025-65 (2026); IRS Notice 2025-12 (2025)
20211.23856886491.2065574831IRS Notice 2025-65 (2026); IRS Notice 2025-12 (2025)
20221.20252065781.1714409585IRS Notice 2025-65 (2026); IRS Notice 2025-12 (2025)
20231.11669358461.0878321254IRS Notice 2025-65 (2026); IRS Notice 2025-12 (2025)
20241.05916510211.0317904930IRS Notice 2025-65 (2026); IRS Notice 2025-12 (2025)
20251.0265311701none (base year)IRS Notice 2025-65 (2026)
Combined QPA indexing factors by base year for items and services furnished in 2025 and 2026, as published in IRS Notice 2025-12 and IRS Notice 2025-65. There is no 2020 base year: when 2019 data is insufficient, the base is the first year the coverage or service code is offered, and the IRS tables start those base years at 2021.

How the standard 2019 base year compounded, year by year

Service yearCombined factor from the 2019 baseIRS source notice
20221.0648523983IRS Notice 2022-11
20231.1466950506IRS Notice 2023-4
20241.2089777165IRS Notice 2024-1
20251.2474117141IRS Notice 2025-12
20261.2805070065IRS Notice 2025-65
Cumulative indexing of a January 31, 2019 qualifying payment amount base, 2022 through 2026, from IRS Notices 2022-11, 2023-4, 2024-1, 2025-12, and 2025-65.

The compounding arithmetic, written out

The factors compound by multiplication. For the standard 2019 base year, the chain to 2026 is:

1.0648523983 (2019 to 2022, IRS Notice 2022-11) × 1.0768582128 (2023, IRS Notice 2023-4) × 1.0543149339 (2024, IRS Notice 2024-1) × 1.0317904930 (2025, IRS Notice 2025-12) × 1.0265311701 (2026, IRS Notice 2025-65), which compounds to the published combined factor of 1.2805070065 (IRS Notice 2025-65).

For a 2021 base year, the chain to 2026 is:

1.0299772040 (2022, IRS Notice 2022-11) × 1.0768582128 (2023, IRS Notice 2023-4) × 1.0543149339 (2024, IRS Notice 2024-1) × 1.0317904930 (2025, IRS Notice 2025-12) × 1.0265311701 (2026, IRS Notice 2025-65), which compounds to the published combined factor of 1.2385688649 (IRS Notice 2025-65).

One precision warning. The combined factors are not always the exact product of the rounded annual factors. Because every published number is rounded to 10 decimal places, multiplying the rounded annual factors yourself can land one unit low in the tenth decimal place for some base years. The IRS publishes the authoritative combined factors in each notice. Use those, as this page does, rather than rebuilding them by hand.

One worked example per base year, indexed to 2026

Take the first one in full. A plan's median contracted rate for a service was $1,000.00 on January 31, 2019. For that service furnished in 2026, the QPA is $1,000.00 × 1.2805070065 (IRS Notice 2025-65) = $1,280.5070065, which rounds to $1,280.51. The rest follow the same pattern:

Base yearBase year median rateCombined factor to 2026 (IRS Notice 2025-65)2026 QPA
2019$1,000.001.2805070065$1,280.51
2021$850.001.2385688649$1,052.78
2022$2,400.001.2025206578$2,886.05
2023$3,000.001.1166935846$3,350.08
2024$125.001.0591651021$132.40
2025$460.001.0265311701$472.20
Worked qualifying payment amount examples for items and services furnished in 2026, using the combined factors from IRS Notice 2025-65. Results are rounded to the cent. Plans are separately permitted to round a disclosed QPA to the nearest whole dollar.

Run your own number through the QPA calculator to see the factor, the source notice, and the year by year path.

Why the indexing arithmetic is worth checking

The plan calculates the QPA and the provider cannot see the contracts behind the median. The indexing step is the exception: it is pure public arithmetic. If a payer discloses a QPA that implies a factor different from the published ones, that is a concrete question to raise in open negotiation or federal independent dispute resolution. And remember the benchmark is a starting point, not an endpoint: 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. Estimate your own award at idrcalculator.com, or have Lido IDR file your disputes for a flat fee per arbitration.

Related reading

How the QPA is calculated under 45 CFR 149.140, in plain language. And how the QPA compares with billed charges, Medicare, and IDR awards.