When Congress passes complicated legislation addressing thorny issues, it can often take years for the federal government to fully implement the policy. The No Surprises Act (NSA) is a perfect example of how passing a law does not immediately lead to policy change. Initially passed in late 2020, it will take years for the Department of Health and Human Services (HHS) and the Centers for Medicare and Medicaid Services (CMS) to fully implement all of its provisions. In August, CMS took an important step towards full implementation of the NSA by finalizing a rule that codified a legal decision from a Texas District Court which changes how much arbiters can weigh the Qualifying Payment Amount (QPA) during the Independent Dispute Resolution (IDR) process.1 While this sounds very technical, (and it is!) this court ruling and subsequent final rule is a small but notable victory for providers.
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