QPA & Compliance

CMS audits identify QPA calculation and disclosure problems

Source: TechTarget · Jacqueline LaPointe · October 22, 2026

Summary published October 25, 2026

TechTarget reports findings involving CareSource and Ohio SERS, including inaccurate qualifying payment amounts and missing disclosures.

What did the audits find?

According to TechTarget’s October 22 report, both audits examined January 2022 through May 2023.

CareSource’s Indiana sample contained 952 QPA determinations with calculation errors: usual-and-customary rates replaced negotiated in-network rates. Some amounts were too high, resulting in consumer overcharges. Auditors also identified 735 instances of missing required QPA information.

The Ohio School Employees Retirement System audit reviewed six air ambulance claims. Two were incorrectly treated as outside the No Surprises Act; disclosures were also incomplete.

What about “ghost rates”?

The report notes that SERS excluded unused negotiated rates. The relevant regulatory language has been vacated and remains under litigation, so this issue should not be presented as settled law.

Why does this matter for providers?

These are specific audit findings, not a nationwide estimate of errors. Our operational takeaway: retain payment notices, QPA disclosures, and information requests alongside each claim so discrepancies can be reviewed in context.