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.
Read full letter here
