QPA Must Reflect Negotiated Market Rates: Excluding Ghost Rates and Including Incentives Under the No Surprises Act

Introduction

Texas Medical Association v. HHS is an en banc Fifth Circuit decision interpreting the No Surprises Act (“NSA”), a statute designed to protect patients from “surprise” balance bills when they receive out-of-network care—especially in emergencies. The NSA shifts the dispute from the patient to an insurer–provider negotiation/arbitration system called the independent dispute resolution process, anchored by a benchmark figure: the qualifying payment amount (“QPA”).

The plaintiffs—Texas Medical Association, Tyler Regional Hospital, L.L.C., Dr. Adam Corley (deceased during appeal), and air-ambulance entities including LifeNet, Incorporated and Air Methods Corporation—challenged key aspects of the agencies’ July 2021 interim-final rule and an August 2022 FAQ. The defendants were the Departments of Health and Human Services, Labor, and Treasury, plus the Office of Personnel Management.

The principal issues were whether agency guidance unlawfully (1) depressed QPAs by allowing “ghost rates” (unnegotiated placeholder rates for services a provider does not actually furnish), (2) depressed QPAs by excluding bonuses/incentives from the “total maximum payment,” and (3) properly excluded one-off single-case agreements (common in air ambulances) from the QPA data set. A final issue concerned the appropriate APA remedy.

Summary of the Opinion

  • Ghost rates: The court held unlawful the agencies’ approach that required inclusion of contracted rates appearing on default fee schedules even when the provider did not actually provide/furnish the service—rejecting the attempted $0-only “fix” in the August FAQs as illogical under the statute’s text.
  • Bonuses/incentives: The court held unlawful the regulation requiring insurers to exclude “risk sharing, bonus, penalty, or other incentive-based or retrospective payments or payment adjustments” from QPA calculations because the NSA demands the “total maximum payment.”
  • Single-case agreements (air ambulances): The court upheld the agencies’ exclusion of one-off single-case agreements from “contracted rates” used to compute the QPA.
  • Remedy: Relying on circuit precedent, the court treated vacatur as the APA’s default remedy and rejected “too-big-to-vacate” arguments, while noting agencies may use enforcement discretion to avoid disruption.

Disposition: AFFIRMED IN PART, REVERSED IN PART, and REMANDED.

Analysis

Precedents Cited

1) Statutory interpretation and definitional skepticism

The court’s “plain text” emphasis echoes the interpretive approach seen in Clackamas Gastroenterology Assocs., P. C. v. Wells, 538 U.S. 440 (2003), cited for criticizing circular statutory definitions. Here, the court treated the NSA’s phrasing (“provided by a provider”) as awkward but meaningful, using it to reject including rates tied to services not actually furnished.

2) Arbitrary-and-capricious review and agency rationales

Although the per curiam grounded its holdings largely in statutory text, the opinion also framed the agencies’ approach as “arbitrary, capricious, and otherwise contrary to law,” especially given the internal inconsistency of excluding $0 ghost rates yet including $1 ghost rates. The court’s skepticism toward after-the-fact agency explanations aligns with SEC v. Chenery Corp., 318 U.S. 80 (1943), invoked in Part III to reject post hoc rationalizations.

3) The scope of “contracted rates” and plan-based context

In upholding exclusion of single-case agreements, the court relied on ordinary meaning and statutory context: “rate” connoting a per-unit price under generally applicable plan terms, not an ad hoc emergency arrangement. The opinion distinguished other regulatory contexts that treat single-case agreements as “contractual relationships,” emphasizing that definitional choices in one NSA subsection do not dictate what counts as “contracted rates” for QPA purposes. The panel’s earlier treatment in Tex. Med. Ass'n v. HHS, 120 F.4th 494 (5th Cir. 2024), reh'g en banc granted, opinion vacated, 138 F.4th 961 (5th Cir. 2025) is referenced as background; the en banc court ultimately agreed with the agencies on this single-case question.

4) APA remedies and vacatur

The remedy discussion is anchored in Cargill v. Garland, 57 F.4th 447 (5th Cir. 2023) (en banc), which the court cites for the proposition that vacatur is the default APA remedy in the Fifth Circuit. Judge Ho’s concurrence, however, raises constitutional concerns about “universal vacatur,” drawing parallels to the Supreme Court’s critique of universal injunctions in Trump v. CASA, Inc., 606 U.S. 831 (2025). He invokes additional limits on the judicial power from TransUnion LLC v. Ramirez, 594 U.S. 413 (2021), and Muskrat v. United States, 219 U.S. 346 (1911), and highlights structural objections similar to those discussed in United States v. Texas, 599 U.S. 670 (2023) (Gorsuch, J., concurring in the judgment), and Trump v. Hawaii, 585 U.S. 667 (2018) (Thomas, J., concurring). Still, he acknowledges circuit precedent and also notes Corner Post, Inc. v. Bd. of Governors of Fed. Rsrv. Sys., 603 U.S. 799 (2024) (Kavanaugh, J., concurring), which states that the APA authorizes vacatur of agency rules.

5) Procedural administrative law (in concurrence)

Judge Oldham’s concurrence reframes the case as a cautionary tale about agencies issuing interim-final rules without notice-and-comment and then attempting to “fix” problems via FAQs. He canvasses procedural doctrines and authorities including Bennett v. Spear, 520 U.S. 154 (1997), Michigan v. EPA, 576 U.S. 743 (2015), DHS v. Regents of the Univ. of Cal., 591 U.S. 1 (2020), and Fifth Circuit law on distinguishing legislative rules and guidance, including Mock v. Garland, 75 F.4th 563 (5th Cir. 2023), Texas v. Equal Emp. Opportunity Comm'n, 933 F.3d 433 (5th Cir. 2019), and Flight Training Int'l, Inc. v. FAA, 58 F.4th 234 (5th Cir. 2023). While these points did not control the per curiam’s merits holdings, they underscore litigation risk where agencies use informal guidance to effect substantive change.

6) Competing interpretation (partial dissent)

Judge Haynes’s partial dissent relies on ordinary meaning for “provide” as “make available,” citing Green Valley Special Util. Dist. v. City of Schertz, 969 F.3d 460 (5th Cir. 2020) (en banc), and reads the NSA’s delegation clause as allowing exclusion of non-fee-for-service incentive payments. The majority rejects these readings as inconsistent with the “furnished” limitation and “total maximum payment” requirement.

Legal Reasoning

1) Ghost rates cannot be used to compute a statutory “median” for services “provided” and “furnished”

The majority treated the QPA definition as textually bounded: the median must be drawn from contracted rates for the “same or similar item or service” that is “provided” and “furnished” in the relevant region. The July Rule’s “each contracted rate” instruction swept in default-fee-schedule entries for services a given provider never performs. In the court’s view, that severs the benchmark from actual market negotiation for delivered care—precisely what the QPA is supposed to approximate.

The court found the agencies’ $0-only carve-out (via FAQ) especially revealing: if $0 rates are excluded because the provider did not truly agree to provide a service for free, then unnegotiated $1 rates (and other placeholder amounts) are similarly non-probative of market negotiation. The court thus treated the rule’s distinction as untenable under the statute.

2) “Total maximum payment” means the entire maximum payment, including incentives/bonuses

The agencies’ exclusion of bonuses and incentive-based adjustments conflicted, in the majority’s view, with the NSA’s demand that the rate reflect the “total maximum payment.” The court relied on ordinary dictionary meaning (“total” as the whole; “maximum” as the greatest attainable), concluding that removing components of payment necessarily understates the contractual maximum.

The agencies argued incentives are often paid as lump sums and not attributable to specific services, and that feasibility concerns warranted exclusion. The majority responded that Congress expressly instructed agencies to “take into account” non-fee-for-service payments in rulemaking, and that administrative difficulty does not justify contradicting clear statutory text—particularly where the agencies chose an interim-final rule without notice-and-comment that could have developed an administrable methodology.

3) Single-case agreements are not “contracted rates” recognized “under” a plan

The court upheld excluding single-case agreements, reasoning that “rate” ordinarily connotes a generalizable per-unit price, while an ad hoc, emergency, out-of-network payment resembles a one-off “price.” Even if contractual in some sense, such arrangements are not “recognized under” the plan in the way network contracts are; they arise precisely because no generally applicable plan term covers the circumstance at in-network rates.

The court also drew structural support from the NSA’s use of a fixed reference date (January 31, 2019) for recognized rates—awkward to apply to one-off emergency encounters—reinforcing that Congress had generally applicable contractual schedules in mind, not event-specific bills.

4) Remedy: vacatur is default; enforcement discretion can prevent patient harm

Applying Cargill v. Garland, the court treated vacatur as the presumptive remedy under 5 U.S.C. § 706. It rejected arguments that vacatur would be too disruptive, stating the APA contains no “too-big-to-vacate” principle. It also relied on the practical availability of agency enforcement discretion to preserve the NSA’s balance-billing protections while corrected QPAs are computed.

Impact

  • QPA methodology must move closer to real negotiated market rates: Insurers cannot rely on default schedule entries untethered to services actually furnished by providers, and cannot omit payment components that make up the contract’s “total maximum payment.”
  • Arbitration dynamics may change materially: The opinion cites evidence that artificially low QPAs corresponded with extraordinarily high arbitration volume and provider win rates. Corrected QPAs may reduce disputes or change settlement leverage.
  • Air ambulance treatment remains distinct: By approving exclusion of single-case agreements, the court prevents high out-of-network, emergency “surprise” prices from being imported into the baseline benchmark meant to reflect typical in-network contracting.
  • Administrative law ripple effects: The opinion reinforces (in the Fifth Circuit) robust judicial willingness to vacate unlawful rules, while Judge Ho’s concurrence preserves an ongoing debate—post-Trump v. CASA, Inc.—about the constitutional legitimacy and scope of universal vacatur.
  • Rulemaking incentives: The repeated theme—highlighted by the majority and developed by Judge Oldham—is that agencies who bypass notice-and-comment may weaken their factual record and invite judicial invalidation when implementation problems surface.

Complex Concepts Simplified

No Surprises Act (NSA)
A federal law that limits what out-of-network providers can bill patients in certain situations and shifts payment disputes to insurers and providers.
Qualifying Payment Amount (QPA)
The statutory benchmark—generally a median in-network contracted rate—used in the NSA’s arbitration and cost-sharing calculations.
Ghost rates
Placeholder rates in a contract’s default fee schedule for services a provider does not actually perform; often not negotiated and may be extremely low.
Total maximum payment
The highest possible amount the plan could pay under the contract for the service—meaning the whole maximum, not a subset excluding incentives or adjustments.
Single-case agreement
An ad hoc, one-off arrangement to pay for a particular out-of-network episode (common for air ambulances), as opposed to general network participation contracts.
Interim-final rule
A rule effective immediately without prior notice-and-comment, permissible only with “good cause.” Its use can limit stakeholder input and undermine the record.
Vacatur (setting aside)
A remedy that nullifies an agency action. In the Fifth Circuit, vacatur is treated as the default APA remedy when agency action is unlawful.
Universal vacatur
The idea that vacating a rule provides relief beyond the parties. Judge Ho questions whether Article III permits this broadly, analogizing to debates over nationwide injunctions.

Conclusion

The en banc Fifth Circuit establishes a clear interpretive baseline for NSA QPA calculations: the QPA must be built from contracted rates that correspond to services actually provided/furnished and must reflect the contract’s “total maximum payment,” including incentive-based compensation. At the same time, the court preserves the agencies’ ability to exclude one-off emergency single-case agreements (notably in air ambulances) from the QPA data set. On remedy, the court reaffirms vacatur as the default APA response to unlawful agency action, rejecting disruption-based pleas and relying on enforcement discretion to protect patients during transition.