The Devil may be in the Details of the Part II No Surprises Act IFR
Health Care Law Brief
NOVEMBER 9, 2021
The “thumb on the scale” QPA presumption may have less of an impact on providers that are “must-haves” for a plan based on clinical importance, or high patient-satisfaction scores. But for other providers and facilities, the impact is likely to be greater. 2] See 86 Fed.
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