Second Release of the FH® NSA Reference File Issued in July

July 21, 2022

In July, FAIR Health is issuing its second release of the FH® NSA Reference File. Refreshed with 12 months of recent data, the product is being used by clients to inform their surprise billing needs under the federal No Surprises Act (NSA).

Effective as of January 1, 2022, the federal NSA applies to health plans in states that do not have a specific state law concerning surprise bills, and to self-insured health plans that are not covered by such state laws. The NSA requires plans to calculate patients’ cost-sharing responsibilities for certain surprise medical bills using the plan’s Qualifying Payment Amount (QPA). The QPA is the payor’s historic median contracted amount for each procedure code in each market and geographic area it covers. When payors have insufficient provider contracts to calculate the applicable median contract amount for a specific service, they must use an independent database to calculate the QPA and determine the patient’s cost-sharing obligations.

Plans can use FAIR Health data in the FH NSA Reference File—recent median allowed amount values for procedure codes at various levels of geographic aggregation—to help calculate the QPA in these situations. In addition, the data may inform the plan’s selection of an initial payment amount to out-of-network providers, potentially reducing disputes and the need for arbitration. The data may also prove useful for all stakeholders in preparation for arbitration and dispute resolution. The data in the FH NSA Reference File can be accessed through a flat file or through FH® Online, which provides convenient, web-based access to the broad suite of FH® Benchmarks. The FH NSA Reference File was first released in January, when the NSA took effect.

FAIR Health President Robin Gelburd stated: “FAIR Health is pleased to issue its second release of the FH NSA Reference File. Many of our clients may experience geographic areas and services for which they have insufficient data to develop a QPA. This product is an easy way to find median values to support surprise billing QPAs, initial payments and arbitration under the NSA.”

For more information about the FH NSA Reference file, contact us by email at or call us at 855-301-3247, Monday through Friday, 9 am to 6 pm ET.