Fifth Circuit Court Invalidates Key Portions of No Surprises Act QPA Calculation Rules

The U.S. Court of Appeals for the Fifth Circuit, in an en banc decision issued on August 11, 2026, largely affirmed a district court ruling that invalidated key portions of federal agencies' rules governing the calculation of the 'qualifying payment amount' (QPA) under the No Surprises Act. This decision has significant implications for how insurers calculate benchmark rates in the Act's independent dispute resolution process.