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No Surprises Act Update: New IDR Guidance
Health Law Advisor, Epstein Becker Green 
[Guidance Overview] Apr. 22, 2022 "The most notable difference between the prior and the new guidance is not in what was added, but what was removed -- namely, the discussion of the importance of 'qualifying payment amounts' (QPA). Interestingly, CMS did not remove or revise the guidance document's direction to arbitrators to more heavily weight QPA in deciding payment disputes between payers and out-of-network providers of air ambulance services." |
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