As I reported previously, the No Surprises Act — which took effect in January 2022 — requires all therapists to give Good Faith Estimates (GFEs) to clients who are not seeking insurance reimbursement (click here to read that article, if you missed it).

While right now GFEs need only be given to clients who are NOT seeking insurance reimbursement, the No Surprises Act actually includes a mandate to give GFEs to ALL clients. However, the requirement to give GFEs to clients seeking insurance reimbursement was delayed pending further guidance on implementation.

In a recent update, the American Psychological Association reports that the Centers for Medicare and Medicaid Services (CMS) plans to issue a forthcoming rule, adding GFE requirements for clients who intend to use their insurance to cover their service. CMS has proposed that, for insured clients, the therapist will need to notify the client’s insurer of the estimated charges, then the insurer would send the client an explanation of benefits based on the provider’s estimate. The CMS has been soliciting feedback from providers about how information would be sent from providers to insurers. The feedback period has now closed, and the CMS is now expected to issue a proposed rule addressing how Good Faith Estimates are to be provided to clients who use insurance to cover their care. To read the full APA article — click here.

Hate having to deal with GFEs? 11 professional associations joined forces to write a letter to the CMS to express concerns about the administrative burden associated with the GFE requirements. To read the letter, click here

So in summary, while the requirement to give GFEs to insured clients has not yet arrived, it appears to be on its way. Stay tuned (and subscribed, if you aren’t already) so you can get updates as they happen.