In my previous posts about non-emergency and emergency services, we discussed how the No Surprises Act works with billing insurance and patients but what if the patient is self-pay or uninsured?
Good Faith Estimates are required to be provided to self-pay patients ahead of scheduled services. If the GFE has a discrepancy of over $400 to what was actually invoiced, the total amount is subject to arbitration. Patients can then dispute invoices on the CMS website by submitting an initiation notice.
Once this process is started, providers must stop all collections until it is fully resolved, but may settle with the patient at any time.
To protect themselves as providers, here are a few steps that practices need to take to comply with the requirements for Good Faith Estimates.
- Post the availability of the GFE.
- This must be a clear notice of the patient’s right to request GFEs on the provider’s website, in the office, and onsite where scheduling or cost questions arise.
- Provide GFEs timely and on the following timeline:
| When is the service scheduled? | Timeline to provide GFEs |
| Between 3 and 10 days in advance | 1 business day |
| Greater than 10 days in advance | 3 business days |
| Not yet scheduled | 3 business days |
- Provide complete GFEs.
- Name/DOB
- Description of primary item
- Listing of CPT, Dx, Provider/Facility
- Name and identifying info for each provider/facility
- Items that will require separate scheduling/GFE
- Requested disclaimers