AFS Analysis of No Surprises Act Ruling Quoted by Healthcare Financial Management Association

The Healthcare Financial Management Association

The Healthcare Financial Management Association (HFMA) recently featured ArentFox Schiff’s analysis of the Fifth Circuit’s en banc decision in Texas Medical Association v. HHS, a ruling that reshapes how Qualifying Payment Amounts (QPAs) are calculated under the No Surprises Act.

The HFMA examined the court’s rejection of “ghost rates” and the exclusion of certain bonus and incentive payments from QPA calculations, changes that could lead to higher QPAs and affect out-of-network reimbursement disputes. In discussing potential implications of the ruling and anticipated agency guidance, the HFMA quoted ArentFox Schiff’s analysis, which noted that providers may “continue to submit claims in a timely manner and preserve all objections to QPA calculations that appear to rely on ghost rates or that categorically exclude bonus/incentive-linked compensation.” 

Read the full article here.

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