Good Faith Estimate Requirements
Request for Information
| Dear RHC Community,
Per the No Surprises Act (NSA), all health care providers, since January 1, 2022, are required to issue Good Faith Estimates (GFEs) to uninsured and self-pay patients who request the summary of expected charges and/or who schedule an appointment 3 or more days in advance. GFEs are to include an estimate of the charges associated with items and services reasonably expected to be furnished to a patient in the “convening facility,” i.e., your RHC. The NSA also included a requirement that GFEs should include items and services expected to be provided along with the primary items/services, even if received from another provider or facility (“co-providers/co-facilities”). CMS delayed enforcement of this initially, but it is set to go into effect January 1, 2023. Additional future provisions, that don’t yet have an effective date, include a requirement that insured patients receive an advanced explanation of benefits (AEOB) from their insurance plan upon scheduling an appointment, utilizing information provided to the plans by individual providers/facilities. Unlike the RHC survey and certification requirements that are enforced by a professional surveyor, these GFE policies are enforced via a patient initiated dispute resolution process, a complex arbitration process which can be undertaken if a patient receives a bill from a provider that is $400 more than the expected charges listed on the GFE. It is unclear how frequently this is occurring at this time. For more information on GFE requirements, please review the CMS resources here or NARHC’s December 2021 webinar and other resources here. Since these provisions were implemented, NARHC has highlighted the administrative burden of such policies. While originally created with positive intent for price transparency purposes, the regulations result in significant time and monetary costs, which will continue to grow with added requirements. NARHC is preparing comments for a multi-department Request for Information (RFI) intended to inform rulemaking for additional GFE and AEOB requirements. We encourage you to contact Sarah Hohman at Sarah.Hohman@narhc.org to share your experiences and challenges in implementing GFE provisions by October 30th, 2022. Sincerely, National Association of Rural Health Clinics |