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The No Surprises Act and Good Faith Estimates

The No Surprises Act and Good Faith Estimates

Important: The information below is specific to using the No Surprises Act Good Faith Estimate & Consent Disclaimer for Health Care Goods and Services template within SimplePractice. It’s the responsibility of each respective provider to ensure their Good Faith Estimates & Consent Disclaimers are in compliance with local, state, and federal guidelines.

The No Surprises Act, also known as No Surprise Billing, will take effect on January 1, 2022. This act is part of a legislative package that was passed in December 2020. This guide is a resource for answering your questions regarding this new legislation.

In this guide, we’ll cover:


No Surprises Act overview

The No Surprises Act, which is part of the Consolidated Appropriations Act of 2021, is designed to protect clients from receiving unexpected medical bills. The Good Faith Estimate provision of the No Surprises Act is designed to give clients an estimate of how much they’ll be charged for the healthcare services they’ll be receiving, prior to their appointment. 


Requirements for providers

As of January 1, 2022, this new legislation applies to all healthcare providers and facilities operating under the scope of a state-issued license or certification. You’re required to share a specific consent document in addition to a Good Faith Billing Estimate, prior to beginning care. 

State-licensed or certified healthcare providers are required to provide a Good Faith Estimate of charges to every new and continuing client who’s either uninsured or isn’t planning to submit a claim to their insurance for the services they’re seeking. You’re also required to inform every uninsured or self-pay client of their right to receive a Good Faith Estimate.

We recommend asking each client whether they have insurance and intend to use it to cover the services that they seek. If the answer to either question is no, they’ll need a Good Faith Estimate prior to their appointment.

Providers are also required to highlight the No Surprises Act on their Professional Website. A link to more information about the No Surprises Act must be present, along with a statement informing clients that they’re entitled to a Good Faith Estimate. To do this, see: Making sure your Professional Website is compliant.


Creating a Good Faith Estimate for a client

Note: The Good Faith Estimate form is available for all subscription tiers, however, only team members with billing access for the client are able to create and send this form.

To generate a Good Faith Estimate for a specific client:

  • Navigate to the client’s Overview page
  • Click New > Good Faith Estimate

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  • Fill out the form
    • Manually update the date range for the estimated services and the number of services you estimate to provide
    • You can click +Add to add other services
    • Use the Notes field to add any additional comments

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  • Click Save
  • Review the document 
    • To edit, click the pen icon
    • To print, click the printer icon
    • To download, click the arrow icon
    • To share with the client for e-signature, click Share

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Once you send the Good Faith Estimate to a client, you can edit it or retract it by clicking the X next to the document under Shared with Client to retract it. This will make the document editable again. 

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Note: The X will only appear next to the document if it’s in the Sent or Viewed status.

If the client has already signed the Good Faith Estimate, the document becomes locked. If you’d like to edit it, you’ll want to create a new Good Faith Estimate for the client. There isn’t a way to delete a locked Good Faith Estimate on a client’s chart.

Note: If you prefer to use the assessment template, Good Faith Estimate for Health Care Items and Services, you can find that in our Template Library. You can also find a PDF version under Forms at the bottom of this guide.


Additional resources


FAQs


Are client signatures required on the consent document or the Good Faith Estimate?

Both the consent document and the Good Faith Estimate aim to protect clients by educating them about the differences between in- and out-of-network coverage. A signature on either document consents to the following:

  • I’m giving up some consumer billing protections under federal law.
  • I may get a bill for the full charges for these items and services, or have to pay out-of-network cost-sharing under my health plan.
  • I fully and completely understand that some or all amounts I pay might not count toward my health plan’s deductible or out-of-pocket limit.

Client signatures aren’t required on either the consent document or the Good Faith Estimate, however, if the client chooses not to sign, the provider can opt out of providing care and the client can proceed to find an in-network provider instead.


Is there a way to be reminded of when it’s time to update a Good Faith Estimate or when the amount estimated has been reached?


Will the Good Faith Estimate for Health Care Items and Services assessment template be made available for customers on the Starter plan?

  • Customers on the Starter plan don’t have access to Assessments. At this time, there are no plans to enable customers on the Starter plan to access the Good Faith Estimates For Health Care Items and Services assessment template. Instead, we recommend that our Starter plan customers download these documents from cms.gov or from the Forms section of this Help Center guide. These documents can still be uploaded to a client’s profile and shared with them via the Client Portal. To do this, please see: How do I upload and share documents for individual clients?

Why can’t I create an intake form to share with clients so they can easily sign the Good Faith Estimate?

It's important to note that the Good Faith Estimate should be an assessment since it’ll include client specific information like their name, date of birth, and diagnosis prior to the client completing the document. In order to accomplish this using an intake form, you'd have to include PHI on an intake form template, which we don’t recommend as it could potentially be shared with other clients in your account.


How do I remove a diagnosis from the Good Faith Estimate?

A diagnosis is required on the Good Faith Estimate once it’s saved to the client’s Overview page. There isn’t a way to remove it from this document.


How do I change the disclaimer text from the Good Faith Estimate?

The text within the disclaimer/consent form is required on the Good Faith Estimate. There isn’t a way to update it.


Is there a way to create a single Good Faith Estimate for a family?

Like all other client documents, a Good Faith Estimate is for one specific client. There isn’t a way to create a Good Faith Estimate for a family if you see multiple members.


Are client email addresses required on the Good Faith Estimate?

Yes, a client email address is required on the Good Faith Estimate. Please see additional information from CMS.gov: The No Surprises Act’s Good Faith Estimates and Patient-Provider Dispute Resolution Requirements.


What if my TIN is my SSN? Is my TIN required on the Good Faith Estimate?

Yes, per CMS.gov your TIN is required on the Good Faith Estimate. If your TIN is your SSN, we recommend reaching out to your legal advisor(s) for advice on how to fill out this form.


If I’m creating a Good Faith Estimate for a client before assigning a diagnosis, what should I do?

Initially, you can use the drop down menu under Diagnosis Code to select None, if a diagnosis hasn’t yet been assigned.

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Once a diagnosis has been assigned, a Good Faith Estimate can be recreated to include the correct diagnosis code.


Does the Good Faith Estimate include all legally required information and disclaimers?

The Good Faith Estimate form includes all the necessary information required on the form as provided by CMS.gov. The disclaimers and information about the form populates when the client views the form in the Client Portal:

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This information doesn’t appear when creating a new Good Faith Estimate form on the client’s Overview page. To view the required information and disclaimers, we recommend creating a Good Faith Estimate for the Jamie Appleseed test client to view the form from the client’s perspective in the Client Portal.


Can I update the expiration date on the Good Faith Estimate?

The expiration date is automatically set to one year out from the day the Good Faith Estimate form is created for a client. Our team is currently working on making the expiration date an editable field.


Forms

You can find a PDF version of both the consent document and the Good Faith Estimate from cms.gov below:

Still have questions?

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