Bulletin No. 2025–47

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2025–47

November 17, 2025

These synopses are intended only as aids to the reader in

identifying the subject matter covered. They may not be

relied upon as authoritative interpretations.

EMPLOYEE PLANS, EXCISE TAX

Notice 2025-65, page 717.

This notice provides the indexing factors to be used by group

health plans and health insurance issuers to calculate the qualifying payment amount (QPA) for items or services provided on

Finding Lists begin on page ii.

or after January 1, 2026, and before January 1, 2027. The QPA

is the basis for determining individual cost sharing for items and

services covered by the balance-billing protections in the No

Surprises Act (NSA), under certain circumstances. The QPA for

a given calendar year is based on information regarding median

rates for certain items and services from prior years and is

indexed based on changes in the consumer price index.

The IRS Mission

Provide America’s taxpayers top-quality service by helping

them understand and meet their tax responsibilities and

enforce the law with integrity and fairness to all.

Introduction

The Internal Revenue Bulletin is the authoritative instrument

of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service

and for publishing Treasury Decisions, Executive Orders, Tax

Conventions, legislation, court decisions, and other items of

general interest. It is published weekly.

It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application

of the tax laws, including all rulings that supersede, revoke,

modify, or amend any of those previously published in the

Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of

internal practices and procedures that affect the rights and

duties of taxpayers are published.

Revenue rulings represent the conclusions of the Service

on the application of the law to the pivotal facts stated in

the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices,

identifying details and information of a confidential nature are

deleted to prevent unwarranted invasions of privacy and to

comply with statutory requirements.

Rulings and procedures reported in the Bulletin do not have the

force and effect of Treasury Department Regulations, but they

may be used as precedents. Unpublished rulings will not be

relied on, used, or cited as precedents by Service personnel in

the disposition of other cases. In applying published rulings and

procedures, the effect of subsequent legislation, regulations,

court decisions, rulings, and procedures must be considered,

and Service personnel and others concerned are cautioned

against reaching the same conclusions in other cases unless

the facts and circumstances are substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code.

This part includes rulings and decisions based on provisions

of the Internal Revenue Code of 1986.

Part II.—Treaties and Tax Legislation.

This part is divided into two subparts as follows: Subpart A,

Tax Conventions and Other Related Items, and Subpart B,

Legislation and Related Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous.

To the extent practicable, pertinent cross references to these

subjects are contained in the other Parts and Subparts. Also

included in this part are Bank Secrecy Act Administrative

Rulings. Bank Secrecy Act Administrative Rulings are issued

by the Department of the Treasury’s Office of the Assistant

Secretary (Enforcement).

Part IV.—Items of General Interest.

This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.

The last Bulletin for each month includes a cumulative index

for the matters published during the preceding months. These

monthly indexes are cumulated on a semiannual basis, and are

published in the last Bulletin of each semiannual period.

The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.

November 17, 2025 

Bulletin No. 2025–47

Part III

26 CFR 54.9816-6T:

Calculating the qualifying

payment amount in 2026

Notice 2025-65

SECTION 1. PURPOSE AND SCOPE

Pursuant to Treas. Reg. § 54.98166T(c), 29 CFR 2590.716-6(c), and 45 CFR

149.140(c), this notice provides the percentage increase for calculating the qualifying payment amounts (QPAs) for items

and services furnished during 2026 for

purposes of sections 9816 and 9817 of the

Internal Revenue Code (Code), sections

716 and 717 of the Employee Retirement

Income Security Act of 1974 (ERISA), and

sections 2799A-1 and 2799A-2 of the Public Health Service Act (PHS Act). These

provisions, added by the No Surprises Act,1

provide protections against surprise medical bills in certain circumstances. Similar

guidance for items and services furnished

during 2022, 2023, 2024, and 2025 was

published in Revenue Procedure 2022-11,

Notice 2022-11, Notice 2023-4, Notice

2024-1, and Notice 2025-12.2

SECTION 2. BACKGROUND

The QPA serves as the basis for calculating patient cost sharing for items or

services subject to the surprise billing provisions of the No Surprises Act in certain

circumstances. The QPA is also one of the

factors considered by a certified indepen-

BASE YEAR OF

QPA ORIGINATION

2019

2021

2022

2023

2024

2025

1

2

dent dispute resolution (IDR) entity to

determine which of two offers submitted

by parties to a payment dispute in the Federal IDR process best represents the value

of a qualified IDR item or service as the

out-of-network rate.

The QPA is generally the median of the

contracted rates recognized by the plan or

issuer on January 31, 2019, for the same or

similar item or service that is provided by

a provider in the same or similar specialty

or a facility of the same or similar facility type and provided in the geographic

region in which the item or service is furnished, increased for inflation. Pursuant

to Treas. Reg. § 54.9816-6T(c), 29 CFR

2590.716-6(c), and 45 CFR 149.140(c),

plans and issuers were first required to

calculate the QPA for items and services

furnished during 2022. Thus, 2019 generally is the base year for items and services

furnished in 2022, increased for all subsequent years. The median contracted rate is

determined with respect to all plans of the

plan sponsor or all coverage offered by the

issuer that are offered in the same insurance market. In general, for years after

2022, the plan or issuer must calculate the

QPA by increasing the QPA determined

for an item or service furnished in the

immediately preceding year by the percentage increase, as published in annual

guidance. QPAs determined based on later

years (for example, QPAs for group health

plans or health insurance issuers not offering coverage in 2019 or items or services

not covered in 2019) are adjusted based on

the year for which the QPA is first determined.

CUMULATIVE PERCENTAGE

INCREASE FOR QPA FROM

BASE YEAR TO 2025

1.2474117141

1.2065574831

1.1714409585

1.0878321254

1.0317904930

1.0000000000

SECTION 3. GUIDANCE

The percentage increase in the CPI-U

over a preceding year is calculated by dividing the average CPI-U for the preceding year

by the average CPI-U for the year immediately prior to the preceding year. For this

purpose, the average CPI-U for a year is the

average of the monthly CPI-Us published by

the Bureau of Labor Statistics of the Department of Labor for the 12-month period ending on August 31 of each year, rounded to

10 decimal places. The percentage increase

in the CPI-U for items and services provided

in 2026 over the preceding year is the average CPI-U for 2025 over the average CPI-U

for 2024. Pursuant to this calculation, the

percentage increase from 2025 to 2026 is

1.0265311701. Further, pursuant to prior

notices, plans and issuers may round any

resulting QPAs to the nearest dollar.

To calculate the adjusted QPA, the prior

year’s adjusted QPA is multiplied by the

percentage increase for the most recent year.

To simplify this calculation, this notice provides cumulative percentage increases. To

calculate the adjusted QPA for items and services furnished in 2026 using the cumulative

percentage increase, the “base year” QPA

is multiplied by the cumulative percentage

increase for the year the base QPA originated.

A plan or issuer may choose whether to use

the cumulative percentage increase or the

percentage increase, but the selected method

must be applied consistently for all QPAs

calculated for items and services furnished

during 2026. A plan or issuer is not permitted

to use one method for certain QPAs and a different method for other QPAs.

PERCENTAGE

INCREASE FOR QPA

FROM 2025 TO 2026

1.0265311701

1.0265311701

1.0265311701

1.0265311701

1.0265311701

1.0265311701

CUMULATIVE PERCENTAGE

INCREASE FOR QPA FROM

BASE YEAR TO 2026

1.2805070065

1.2385688649

1.2025206578

1.1166935846

1.0591651021

1.0265311701

The No Surprises Act was enacted as Title I of Division BB of the Consolidated Appropriations Act, 2021, Pub. L. 116-260, 134 Stat. 1182 (2020).

Revenue Procedure 2022-11, 2022-3 IRB 449; Notice 2022-11, 2022-14 IRB 939, Notice 2023-4, 2023-2 IRB 321, Notice 2024-1, 2023-2 IRB 314, and Notice 2025-12, 2025-8 IRB 813.

Bulletin No. 2025–47

717

November 17, 2025

See Notice 2024-1 and Notice 2025-12

regarding the application of these percentage increases.

SECTION 4. EFFECTIVE DATE

The effective date of this notice is January 1, 2026.

November 17, 2025

SECTION 5. DRAFTING

INFORMATION

contact 202-317-5500 (not a toll-free

number).

The principal author of this notice is

the Office of Associate Chief Counsel

(Employee Benefits, Exempt Organizations, and Employment Taxes). For further information regarding this notice,

718

Bulletin No. 2025–47

Definition of Terms

Revenue rulings and revenue procedures

(hereinafter referred to as “rulings”) that

have an effect on previous rulings use the

following defined terms to describe the

­effect:

Amplified describes a situation where

no change is being made in a prior published position, but the prior position is

being extended to apply to a variation of

the fact situation set forth therein. Thus,

if an earlier ruling held that a principle

applied to A, and the new ruling holds that

the same principle also applies to B, the

earlier ruling is amplified. (Compare with

modified, below).

Clarified is used in those instances

where the language in a prior ruling is

being made clear because the language

has caused, or may cause, some confusion. It is not used where a position in a

prior ruling is being changed.

Distinguished describes a situation

where a ruling mentions a previously published ruling and points out an essential

difference between them.

Modified is used where the substance

of a previously published position is being

changed. Thus, if a prior ruling held that a

principle applied to A but not to B, and the

new ruling holds that it applies to both A

and B, the prior ruling is modified because

it corrects a published position. (Compare

with amplified and clarified, above).

Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions.

This term is most commonly used in a ruling

that lists previously published rulings that

are obsoleted because of changes in laws or

regulations. A ruling may also be obsoleted

because the substance has been included in

regulations subsequently adopted.

Revoked describes situations where the

position in the previously published ruling

is not correct and the correct position is

being stated in a new ruling.

Superseded describes a situation where

the new ruling does nothing more than

restate the substance and situation of a

previously published ruling (or rulings).

Thus, the term is used to republish under

the 1986 Code and regulations the same

position published under the 1939 Code

and regulations. The term is also used

when it is desired to republish in a single

ruling a series of situations, names, etc.,

that were previously published over a

period of time in separate rulings. If the

new ruling does more than restate the substance of a prior ruling, a combination of

terms is used. For example, modified and

superseded describes a situation where the

substance of a previously published ruling

is being changed in part and is continued

without change in part and it is desired to

restate the valid portion of the previously

published ruling in a new ruling that is

self contained. In this case, the previously

published ruling is first modified and then,

as modified, is superseded.

Supplemented is used in situations in

which a list, such as a list of the names of

countries, is published in a ruling and that

list is expanded by adding further names

in subsequent rulings. After the original

ruling has been supplemented several

times, a new ruling may be published that

includes the list in the original ruling and

the additions, and supersedes all prior rulings in the series.

Suspended is used in rare situations

to show that the previous published rulings will not be applied pending some

future action such as the issuance of new

or amended regulations, the outcome of

cases in litigation, or the outcome of a

Service study.

Abbreviations

The following abbreviations in current

use and formerly used will appear in

material published in the Bulletin.

A—Individual.

Acq.—Acquiescence.

B—Individual.

BE—Beneficiary.

BK—Bank.

B.T.A.—Board of Tax Appeals.

C—Individual.

C.B.—Cumulative Bulletin.

CFR—Code of Federal Regulations.

CI—City.

COOP—Cooperative.

Ct.D.—Court Decision.

CY—County.

D—Decedent.

DC—Dummy Corporation.

DE—Donee.

Del. Order—Delegation Order.

DISC—Domestic International Sales Corporation.

DR—Donor.

E—Estate.

EE—Employee.

E.O.—Executive Order.

ER—Employer.

Bulletin No. 2025–47

ERISA—Employee Retirement Income Security Act.

EX—Executor.

F—Fiduciary.

FC—Foreign Country.

FICA—Federal Insurance Contributions Act.

FISC—Foreign International Sales Company.

FPH—Foreign Personal Holding Company.

F.R.—Federal Register.

FUTA—Federal Unemployment Tax Act.

FX—Foreign corporation.

G.C.M.—Chief Counsel’s Memorandum.

GE—Grantee.

GP—General Partner.

GR—Grantor.

IC—Insurance Company.

I.R.B.—Internal Revenue Bulletin.

LE—Lessee.

LP—Limited Partner.

LR—Lessor.

M—Minor.

Nonacq.—Nonacquiescence.

O—Organization.

P—Parent Corporation.

PHC—Personal Holding Company.

PO—Possession of the U.S.

PR—Partner.

PRS—Partnership.

i

PTE—Prohibited Transaction Exemption.

Pub. L.—Public Law.

REIT—Real Estate Investment Trust.

Rev. Proc.—Revenue Procedure.

Rev. Rul.—Revenue Ruling.

S—Subsidiary.

S.P.R.—Statement of Procedural Rules.

Stat.—Statutes at Large.

T—Target Corporation.

T.C.—Tax Court.

T.D.—Treasury Decision.

TFE—Transferee.

TFR—Transferor.

T.I.R.—Technical Information Release.

TP—Taxpayer.

TR—Trust.

TT—Trustee.

U.S.C.—United States Code.

X—Corporation.

Y—Corporation.

Z—Corporation.

November 17, 2025

Numerical Finding List1

Bulletin 2025–47

Announcements:

2025-19, 2025-29 I.R.B. 191

2025-20, 2025-31 I.R.B. 271

2025-21, 2025-32 I.R.B. 312

2025-24, 2025-36 I.R.B. 359

2025-25, 2025-36 I.R.B. 360

2025-26, 2025-40 I.R.B. 444

Notices:

2025-32, 2025-27 I.R.B. 1

2025-33, 2025-27 I.R.B. 4

2025-34, 2025-27 I.R.B. 6

2025-35, 2025-27 I.R.B. 8

2025-31, 2025-28 I.R.B. 14

2025-36, 2025-30 I.R.B. 192

2025-37, 2025-30 I.R.B. 198

2025-40, 2025-31 I.R.B. 266

2025-39, 2025-32 I.R.B. 308

2025-28, 2025-34 I.R.B. 316

2025-41, 2025-34 I.R.B. 325

2025-42, 2025-36 I.R.B. 351

2025-43, 2025-36 I.R.B. 356

2025-44, 2025-37 I.R.B. 386

2025-45, 2025-37 I.R.B. 388

2025-38, 2025-38 I.R.B. 392

2025-47, 2025-40 I.R.B. 441

2025-51, 2025-41 I.R.B. 448

2025-52, 2025-41 I.R.B. 474

2025-54, 2025-41 I.R.B. 479

2025-46, 2025-43 I.R.B. 533

2025-50, 2025-43 I.R.B. 542

2025-53, 2025-43 I.R.B. 624

2025-55, 2025-43 I.R.B. 625

2025-49, 2025-44 I.R.B. 627

2025-57, 2025-45 I.R.B. 692

2025-61, 2025-45 I.R.B. 693

2025-63, 2025-46 I.R.B. 709

2025-65, 2025-47 I.R.B. 717

Revenue Procedures:

2025-22, 2025-30 I.R.B. 200

2025-24, 2025-31 I.R.B. 273

2025-25, 2025-32 I.R.B. 311

2025-26, 2025-33 I.R.B. 315

2025-28, 2025-38 I.R.B. 393

2025-30, 2025-42 I.R.B. 489

2025-27, 2025-44 I.R.B. 646

2025-32, 2025-45 I.R.B. 695

Revenue Rulings:

2025-13, 2025-28 I.R.B. 11

2025-14, 2025-32 I.R.B. 300

2025-15, 2025-32 I.R.B. 302

2025-16, 2025-35 I.R.B. 342

2025-17, 2025-36 I.R.B. 349

2025-18, 2025-37 I.R.B. 365

2025-19, 2025-41 I.R.B. 445

2025-20, 2025-41 I.R.B. 447

2025-21, 2025-45 I.R.B. 690

Treasury Decisions:

10021, 2025-31 I.R.B. 264

10031, 2025-32 I.R.B. 304

10033, 2025-40 I.R.B. 411

10035, 2025-42 I.R.B. 484

10034, 2025-43 I.R.B. 523

10036, 2025-43 I.R.B. 525

Proposed Regulations:

REG-125710-18, 2025-30 I.R.B. 263

REG-107459-24, 2025-32 I.R.B. 313

REG-132805-17, 2025-35 I.R.B. 342

REG-108822-25, 2025-36 I.R.B. 361

REG-129260-16, 2025-39 I.R.B. 410

REG-108673-25, 2025-42 I.R.B. 494

REG-110032-25, 2025-42 I.R.B. 495

REG-112261-24; REG-116085-23, 2025-42

I.R.B. 522

REG-109742-25, 2025-46 I.R.B. 712

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2025–27 through 2025–52 is in Internal Revenue Bulletin

2025–52, dated December 22, 2025.

1

November 17, 2025

ii

Bulletin No. 2025–47

Finding List of Current Actions on

Previously Published Items1

Bulletin 2025–47

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2025–27 through 2025–52 is in Internal Revenue Bulletin

2025–52, dated December 22, 2025.

1

Bulletin No. 2025–47

iii

November 17, 2025

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue

Bulletins are available at www.irs.gov/irb/.

We Welcome Comments About the Internal Revenue Bulletin

If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it,

we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page

www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave.

NW, IR-6230 Washington, DC 20224.