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The January 2022 Surprise of Good Faith Estimates Requirements

Curt and Katie chat about the No Surprises Act, specifically how to navigate the requirement for clinicians to provide Good Faith Estimates to clients. We talk about the impact of Good Faith Estimates on the intake process, potential complications when providing these estimates to your patients, and suggestions for how to simplify and systemize this requirement.    

In this episode of the Modern Therapist’s Survival Guide we talk about the No Surprises Act and the Good Faith Estimate Requirement

When we heard about the planned implementation of these new requirements, we decided to dive into the legislation and articles from professional associations to understand what we actually need to do starting January 1, 2022.

What is the No Surprises Act and the Good Faith Estimate (GFE) Requirement?

• The goal of the No Surprises legislation is to avoid surprising patients with large medical bills
• There are benefits and challenges with the requirement to provide good faith estimates to our clients
• The Good Faith Estimate requirement is to provide the estimated cost of services (fee times number of sessions) at the beginning of treatment (if asked) and at least annually, if needed

How will the Good Faith Estimate Requirement impact the Intake Process for Therapy?

• We are required to determine whether someone is hoping to get insurance reimbursement
• We must communicate the ability to obtain a written good faith estimate from providers
• We are required to estimate the number of sessions and total cost of treatment
• We talk about when you may need to provide a new good faith estimate (and explain changes)
• We provided a suggestion to start with a GFE for the intake session and then provide a second GFE after that initial session

Potential Complications Curt and Katie see for Therapists Providing Good Faith Estimates

• The requirement for diagnosis very early in treatment
• The requirement for a diagnosis written on paper – both for folks who don’t know or have not asked before, as well as for folks who do not want a written diagnosis
• Concerns related to putting forward the total cost of therapy for the year
• The elements of bureaucracy that could negatively impact the therapeutic relationship
• The No Surprises Act legislation isn’t finalized and may have additional components or changes

Our Suggestions to Systematize the Good Faith Estimate (GFE) Requirement for Therapists

• Consider coordinating the timeline for updating GFEs, treatment plans, frequency of sessions, progress in treatment, and a reassessment of the sliding scale
• Think through how you talk about diagnosis and treatment planning ahead of time
• The idea to create some sort of mechanism for folks to either decline a GFE or to request an oral versus paper GFE
• Use recommended language to create your notice for your office as well as on your website
• Create your own template to simplify the process, including a boiler plate GFE for your intake
• Create a template for GFEs for on-going treatment

Resources for Modern Therapists mentioned in this Podcast Episode:

We’ve pulled together resources mentioned in this episode and put together some handy-dandy links. Please note that some of the links below may be affiliate links, so if you purchase after clicking below, we may get a little bit of cash in our pockets. We thank you in advance!

APA Article: New Billing Disclosure Requirements Take Effect in 2022

Suggested Notification Language for Good Faith Estimates

Template for a Good Faith Estimate

Good Faith Estimate Legislation Language from the No Surprises Act

Federal Register: Requirements Related to Surprise Billing; Part II

CMS.gov: Requirements Related to Surprise Billing; Part II, Interim Final Rule with comment period

Relevant Episodes of MTSG Podcast:

Should Private Practice Therapists Take Insurance?

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