The median
The law took the surprise out of your bill. It left the price with us.
Congress wrote the No Surprises Act to end the bill no one saw coming. In an emergency, out of network, your share is now figured as if you had stayed in network. The law never asked us to show you the price. The surprise is gone. The price is still a private matter.
Your share is figured on the median in-network rate. We define it. We calculate it from our own contracts, plan by plan, or across whatever set of plans an employer signs off on.* Then we tell you the answer.
*Our contracts include rates for services our doctors never provide, and leave out the bonuses we pay them. In 2026 a court told us to stop counting that way. We are reviewing the court.
Of everything the family owns, this number is what it guards most closely. Not because it is large, but because the rules around it are complicated, and the complication is the lock.
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Seen here: the median, kept safe.†
†Two locks: one on the number, one on how we got it.
Between us, there is no in-network rate. Every doctor in the network has a rate of their own, and no two need agree. The network itself has no price but one: the one you pay to get in.
The real answer
How is the QPA calculated?
The plan or insurer calculates it itself, from its own contracts. It is the median of the rates it had contracted as of January 31, 2019, for the same or a similar service, by a provider in the same or a similar specialty, in the same region, across its plans in the same market (for a self-insured employer plan, other self-insured plans), raised for inflation since then (42 U.S.C. § 300gg-111(a)(3)(E)). On August 11, 2026, the full federal appeals court for the Fifth Circuit held the federal rule for that calculation unlawful in two respects: it counted rates for services a provider never plans to provide, and it left out bonus and incentive payments (No. 23-40605, 5th Cir., en banc).