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

The U.S. Court of Appeals for the Fifth Circuit issued an en banc decision largely affirming a lower court's ruling that invalidated significant parts of federal agencies' rules for calculating the 'qualifying payment amount' (QPA) under the No Surprises Act. This decision is expected to have substantial implications for how insurers determine benchmark rates in the Act's independent dispute resolution process.