How the qualifying payment amount is calculated in 2026

The 2026 formula

2026 QPA = 2019 median contracted rate × 1.2805070065

The IRS publishes the indexing factor every year. For 2026 the one-year increase over 2025 is 1.0265311701, and the cumulative increase from the 2019 base year is 1.2805070065, effective January 1, 2026. Each one-year increase is the average CPI-U for the prior year divided by the average CPI-U for the year before that.

• 2022 services: 1.0648523983 (2019 → 2022)
• 2025 services: 1.2474117141 (2019 → 2025)
• 2026 services: 1.2805070065 (2019 → 2026)

Worked examples

• $400 median in 2019 × 1.2805070065 = $512.20 → 2026 QPA $512
• $1,250 × 1.2805070065 = $1,600.63 → $1,601
• $2,800 × 1.2805070065 = $3,585.42 → $3,585

Run it backwards to test a payer: divide the disclosed 2026 QPA by 1.2805070065 and you get the 2019 median the plan is implicitly claiming. If that implied median is well below what your group or comparable in-network groups were actually paid for the code in 2019, the QPA deserves a challenge.

What the median has to match

• Same or similar item or service — by service code, including modifiers that change payment
• Same provider specialty where the plan's contracted rates vary by specialty
• Same geographic region as defined in the regulations
• Same insurance market — individual, small group, large group, or self-insured — across all of the sponsor's plans or the issuer's coverage in that market

With an even number of contracted rates, the median is the average of the two middle rates.

When the plan didn't have enough 2019 data

"Sufficient information" means at least three contracted rates on January 31, 2019. Without that, the plan must use an eligible database to find the median in-network allowed amount for the service in the region for a later base year, then index that number forward by CPI-U. Newly covered services follow the same database route.

How to audit a QPA

1. Pull the QPA disclosed with the initial payment or denial — plans are required to provide it.
2. Back out the implied 2019 median with the factor above.
3. Compare it to your own 2019-era contracted and in-network history for the code and region.
4. Request the calculation details the regulations entitle you to, such as whether an eligible database was used.
5. Raise the discrepancy in open negotiation and document it for the IDR entity.

The QPA in IDR

The QPA is one factor a certified IDR entity must consider. It is not a cap: providers prevail in roughly 88% of federal determinations that reach a decision, according to CMS public data. Offers anchored only on the QPA leave money on the table; offers anchored on billed charges are excluded by statute. See the QPA explained for the full list of factors.

FAQ

What is the QPA inflation factor for 2026?

For items and services furnished in 2026, the cumulative CPI-U factor from the 2019 base year is 1.2805070065. The one-year factor from 2025 to 2026 is 1.0265311701 (IRS, Internal Revenue Bulletin 2025-47).

How is the QPA calculated?

The plan takes the median of its contracted rates on January 31, 2019 for the same or similar service, provider specialty, geographic region and insurance market, then multiplies it by the cumulative CPI-U factor for the service year. Plans may round to the nearest dollar.

What if the plan had fewer than three contracted rates in 2019?

The plan lacks sufficient information and must use an eligible database to determine the median in-network allowed amount for a later base year, then index it forward by CPI-U.

Is the QPA the most an IDR entity can award?

No. The QPA is one factor the certified IDR entity considers alongside the provider's training and experience, case complexity, market share, and prior contracting history. It is not a ceiling.

Sources: IRS Internal Revenue Bulletin 2025-47 (2026 QPA indexing factors); 26 CFR 54.9816-6T; IRS 2022 QPA guidance; CMS Federal IDR public reporting. IDR Filings is not a law firm and this page is not legal advice.