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Health & Welfare Plans Newsletter

BULLETIN
January 13, 2026

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[Official Guidance]

Text of IRS Notice 2025-65: Calculating the Qualifying Payment Amount in 2026 (PDF)

"This notice provides the percentage increase for calculating the qualifying payment amounts (QPAs) for items and services furnished during 2026 for purposes of ... the Internal Revenue Code ... [ERISA], and ... the Public Health Service Act.... The QPA serves as the basis for calculating patient cost sharing for items or services subject to the surprise billing provisions of the No Surprises Act in certain circumstances. The QPA is also one of the factors considered by a certified independent dispute resolution (IDR) entity to determine which of two offers submitted by parties to a payment dispute in the Federal IDR process best represents the value of a qualified IDR item or service as the out-of-network rate." [BenefitsLink note:  This Notice was issued shortly after the government shutdown ended in Nov. 2025, and was not publicized by IRS.  Thanks to readers at Evernorth for bringing it to our attention.]  MORE >>

Internal Revenue Service [IRS]

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BenefitsLink® Health & Welfare Plans Newsletter, ISSN no. 1536-9595.

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