Nov 17, 2021
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.