Updated FAQs Clarify No Surprises Act & ACA Cost-Sharing Rules

On July 30, 2025, federal agencies released new FAQs (“Part 71”) to guide the continued implementation of the No Surprises Act and key ACA provisions. This update follows important court rulings that affected how out-of-network payments and Qualified Payment Amounts (QPAs) are handled.

The No Surprises Act protects patients from unexpected out-of-network medical bills, especially for emergency and ambulance services, and establishes a dispute resolution process for billing disagreements.

Part 71 emphasizes that plans must continue to comply with cost-sharing limits under the ACA, disclose QPA information clearly, and make timely claims decisions within 30 days, even during ongoing regulatory changes.

For employers and plans, this means continuing to follow the IDR process and communicating promptly with enrollees to ensure protection from surprise bills.

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