We simulated qualifying payment amount calculations using our proprietary data asset with over 78 million member life years to better understand the No Surprise Act. The Department of Health and Human Services (HSS) made key decisions and an interim final rule during our analysis on:

• The median contracted rate
• The “cohort” for sampling median contract rates

We provide insights into the expected implications of the interim final rule, as well as potential options that HHS may consider as it reviews comments and finalizes provisions of this rule.

This report was commissioned by UnitedHealth Group (UHG).