Big Surprise: GFE Requirements

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January 1st is just two days away! Many anesthesia and pain practices are scrambling to implement the Good Faith Estimates that are now required under the No Surprises Billing Act.  This week government officials issued a FAQ document regarding the process and what is expected as of January 1st
To read the entire document click here

A few things we would like to highlight:

  1.  The good faith estimate (GFE) applies to all uninsured (self-pay) individuals and must be given by all providers and facilities who schedule services to the individual patient within three days prior to the date of their scheduled service.
  2. Anesthesia groups can qualify to be included in what is known as the “convening provider or facility” but that notice must individually list the items or services with a reasonable expected price.  You will need to work with your facilities to establish a system for estimates.  Beware, you are now putting your fees out publicly so preserving the base plus time formula is recommended.  You may need to work with your facilities to use estimated OR block time to calculate the time component. 
  3. The convening facility is required to notify the co-providers within three days, and you must retain the GFE written notice in the individual patient file either electronically or on paper. For those of you using billing companies, this will be especially challenging as they normally do not create an account until after the date of service.
  4. The GFE must reflect the expected charges, including any expected discounts or other relevant adjustments that may be applied to their bill.  The requirements for the GFE are:
    • The patient’s name and date of birth.
    • A description of service(s) being furnished to the patient.
    • An itemized list of items and/or services that are “reasonably expected” to be furnished.
    • Expected charges associated with each service(s).
    • Your name, National Provider Identifier, Tax Identification Number, and the location where the services will be provided.
    • A disclaimer stating there may be additional items or services recommended as part of the treatment that may be scheduled separately and are not reflected in the good faith estimate.
    • A disclaimer stating the information provided in the good faith estimate is only an estimate and those actual items, services, or charges may differ from the good faith estimate; and
    • A disclaimer that the good faith estimate does not require the private pay patient to obtain other services from you.

If this all looks like a financial consent, guess what, it is exactly what you are doing! You are required to put the detail and the costs associated with the service. You need to give the patient a copy of this information, and you must retain a copy for your records.
Happy New Year! 2022 is ringing in with some unique challenges for our industry. If we can help, please contact us. 

The ACE Team





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