Why do providers say the QPA understates the market?

Because it is frozen to the payer's own January 2019 contract median and indexed by CPI-U, which has trailed negotiated rate growth, and because the median counts rarely-used low contracts equally with the contracts that pay most claims.

Does the QPA at least protect patients?

Yes. Patient cost sharing on protected claims is computed from the QPA, which keeps deductibles and coinsurance anchored to a contracted-rate benchmark instead of billed charges. The fairness fight is about provider payment, not patient bills.

What is the strongest evidence on whether the QPA is fair?

The published arbitration record: certified IDR entities choosing between real offers picked providers 85.8 percent of the time at typical awards around 4.7 times the QPA, across 3.39 million published disputes.

Answers / Is the QPA fair

Is the QPA a fair market rate?

The qualifying payment amount is the payer's own median contracted rate from January 31, 2019, indexed by CPI-U rather than by healthcare prices. Providers argue that construction understates the market; payers argue it reflects real negotiated rates. The published No Surprises Act record settles the argument: arbitrators, choosing between offers, land on awards around 4.7 times the QPA in the typical decided dispute.

The provider case against the QPA

Three structural complaints. The vintage: the base is frozen at January 31, 2019, and CPI-U indexing has lagged the growth in negotiated commercial rates, so the gap widens every year. The authorship: the QPA is computed by the payer from the payer's own contracts, with the provider unable to see inside the calculation beyond what disclosure rules force out. And the median-of-rates design: every contracted rate counts once, whether it paid one claim or ten thousand, which lets rarely-used low contracts drag the median below what the plan actually pays in volume.

The payer case for it

The defense is simpler: the QPA is built from real negotiated rates rather than aspirational charges, medians resist outliers, and a stable regional benchmark keeps patient cost sharing predictable, which is the No Surprises Act's first job. On the cost-sharing side that argument has won: the QPA does set what patients owe, and nobody seriously disputes that a contracted-rate median beats billed charges for that purpose.

What the record says

On the payment side, the record is one-sided. Certified IDR entities, forbidden from considering billed charges and no longer allowed to presume the QPA correct, picked the provider's offer in 85.8 percent of published decisions, with typical awards around 4.7 times the QPA. Arbitrators comparing the QPA against documented acuity, credentials, and market context keep concluding the fair number sits well above the anchor.

What this means operationally

Treat the QPA as what it is: the floor for patient cost sharing and the opening bid in a payment negotiation. A group that accepts QPA-level payment on protected claims is settling at the anchor in a forum where the typical decided outcome runs multiples above it. The fix is process: disclosures demanded, methodology requested, offers built on the statutory factors, and deadlines kept. Lido IDR runs that process for a flat fee per arbitration.

Do not settle at the anchor

The record puts fair value well above the QPA. Lido IDR gets claims there for a flat fee per arbitration. Talk to an IDR specialist.