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Good Faith Estimate Requirements
| Dear RHC Community,
Per the No Surprises Act (NSA), all health care providers, including those who work in RHCs, are required to issue Good Faith Estimates (GFEs) to uninsured and self-pay patients who schedule an appointment 3 or more days in advance or request the summary of expected charges. This requirement has been in place since January 1, 2022. 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. In case you missed NARHC’s resources on GFEs, or haven’t seen the the recent updates related to how sliding fee scales interface with GFEs, please check out the resource guide here. As a reminder, CMS delayed enforcement of “phase II” of the GFE requirements, pending future rulemaking. This provision from the No Surprises Act would require GFEs to 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”). 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. In addition to NARHC’s resource guide, you can review CMS resources here, as well as NARHC’s Technical Assistance Webinars. With any questions, please contact Sarah Hohman at Sarah.Hohman@narhc.org. Sincerely, National Association of Rural Health Clinics |