Highlights of Internal Revenue Bulletin 2025-46 – 11/17/2025

Posted by Lee Reams Sr., BSME, EA on

In this release, we cover highlights from IRS Bulletin 2025-47, including updated QPA indexing factors for 2026 services under the No Surprises Act. Learn more about key changes and impacts.

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EMPLOYEE PLANS, EXCISE TAX

 Notice 2025-65, page 717.

This notice provides the indexing factors to be used by group health plans and health insurance issuers to calculate the qualifying payment amount (QPA) for items or services provided on or after January 1, 2026, and before January 1, 2027. The QPA is the basis for determining individual cost sharing for items and services covered by the balance-billing protections in the No Surprises Act (NSA), under certain circumstances. The QPA for a given calendar year is based on information regarding median rates for certain items and services from prior years and is indexed based on changes in the consumer price index.