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The "No Surprises Act"

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29 comments

  • Arthur L. Wagner

    Hello, I second Angela's question.

    There is a new federal CMS rule requiring that many or most providers give clients a Good Faith Estimate of their costs prior to services being provided or upon request by clients. This rule is related to the No Surprises Act and will be affecting healthcare providers starting 1/1/2022.

    How is SP preparing to help providers automate sending clients a Good Faith Estimate of the costs of services they'll receive (in the next session or the next 12 months)? For many of us the blanks can be pre-filled in because most of the data fields will be the same for every client.

    https://www.apaservices.org/practice/legal/managed/billing-disclosure-requirements?fbclid=IwAR2G-AsWE_ZdQ9MQbOqHzmphnbBrlqlK5uIkv6EcOV9u7mRi8VVW0m1itTo

    https://www.clinicalsocialworkassociation.org/Announcements/12193411

    I urge SP to expedite the capability to provide GFE's because we will be required to begin providing them in less than a month!!

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  • Mira Silberg

    Hello, I agree with both requests above. How can SP help us and implement a template for providers.?

    thanks, Mira 

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  • Sara

    Hi everyone,

    We understand that the No Surprises Act requires providers to send a specific Consent Document and a Good Faith Billing Estimate to clients prior for them to review and sign. We have gone ahead and added this template as an Assessment template in our Template Library. You can now go to Notes and Forms > Template Library to add the Good Faith Estimate for Health Care Items and Services template to your account.
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  • Katherine Aronoff

    Thank you! It's great to have a template. How do we fill out the template to then send to the client? Does it let you edit it before you send it to a client to put the relevant info? It seems like the system would just send the blank form as it is now, but I'm sure I'm missing something.

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  • Kavita Comoglio

    I don't see Good Faith Estimate for Health Care Items and Services in Notes and Forms > Template Library. Does anyone else see it?

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  • Kavita Comoglio

    Nevermind. I see it now.

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  • Rebecca Johnson Osei

    This doesn't feel very helpful as-is but I think we can create our own by making and editing a duplicate. We cannot send this to clients as-is because it would require THEM to input their diagnostic code, service codes, and cost estimate themselves (pretty much the opposite of what needs to happen). I am playing around with it now because, as someone mentioned, for our new clients we will likely be giving a deferred diagnosis, and the cost estimate portion won't vary much per client. You will definitely have to create a version of this for every service you offer (ex; therapy, assessment, psychiatry) but those should be reusable once created.

    Since this must be done yearly, I would love to see SP create a version that auto-fills with the client's data the same way a Superbill does. It does not seem that we, as providers, can add those type of auto-fill fields but maybe I just don't know how? I would likely label such a form as something like "Good Faith Estimate Update" in my templates so I knew to send that version for the follow-ups, versus the bank version that does not have the client's data or updated diagnosis included.

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  • Arthur L. Wagner

    I thank SP for creating a basic template.

    I'm not sure yet how to use this assessment. It looks like I can complete it for the client in their overview page and sign it. Then I'd have to download it, upload it to the clients document storage, and then share it with the client via the portal. All that seems ridiculously complex to do for each client.

    SP can you improve this process?

    There are a number of changes I'm making to their template to make it easier to use.

    Simplify the address so it is just one field so we can copy and paste that from the client's overview page.

    (We can also copy and paste their date of birth, phone number, and email.)

    I'm creating another header and paragraph text section for each of these topics:

    Other Possible Fees (This lists fees for no show, late cancelation, report writing, depositions and court appearances, and other forms of treatment, which include family therapy 90847, neurofeedback, sessions related to legal cases or worker's comp; 30-minute session extensions for longer sessions, non-regular office hours 99050, and evening and weekend sessions 99051, etc.)

    If Using Insurance (This GFE form could be confusing if a client want to use insurance, so this section will explain that.)

    Length or Duration of Treatment and Frequency of Sessions (This describes typical frequency and duration of treatment and defines the assumptions used in the GFE.)

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  • Sara

    Hi everyone,

    For all of these requests to edit the Good Faith Estimate for Health Care Items and Services template, I recommend creating an Ideas and Suggestions Board post so that our Product Team that focuses on notes and documents can view these request and make changes to the template as needed: https://simplepractice.uservoice.com/forums/918553-simplepractice-feedback

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  • Mallory Haney Veres

    Has anyone figured out how to complete the Good Faith Estimate for the client?  I'm working with it in a test client chart, and it's sending to the client to complete, not allowing me to complete before sending to them.

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  • Nyshia Johnson, PsyD, LCSW

    I am unable to locate the form in the template library... 

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  • Mira Silberg

    I think it’s near the bottom of the page if I remember correctly

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  • Jennifer Ingram

    Could the Superbill be modified to meet these requirements? It already (should) have most of the required demographic information about the practice, as well as the client info and diagnosis. For now, I've embedded the language of the GFE according to my practice into the text of the outgoing email notifying clients that their superbill is attached. Another nice option would be if GFE statements could be attached to the appointment reminders. Automation is my BFF. Alternately, could clients sign a waiver stating that they have received the GFE, they understand it, they know it is "good" for 12 months, and that they do not want to receive it prior to each appointment?

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  • Rebecca Johnson Osei

    Petra and Arthur, this ONLY applies to clients who are not suing insurance. It does not need to be submitted to the insurance company nor does it need to contain any additional language about insurance other than what is already included. Since this is an estimate for services, it also does not need to include any extraneous information such as cancellation fees, which you would still include and disclose in your Informed Consent (in fact, I wonder if that could be problematic). The whole purpose of the form is to be simple and straight forward (i.e., 12 sessions of CBT will cost you $____).

    Mallory, as of now you will have to edit the version SP is offering to include pertinent info such as your service codes and the client's diagnosis. This may be similar for new patients, since we usually will be deferring diagnosis and recommending a typical therapy course, but you'll have to updated this yearly for clients who last longer than a year, and at that time you'll have to make one by hand for every individual client as diagnosis and needs change from the initial estimate.

    Jennifer, you only need to do this ONCE A YEAR: before the start of treatment (and now for existing clients), and then again a year later. You don't need any kind of waiver for this - the yearly requirement is what is already stipulated by the rule.

    As an FYI to all: some are arguing that this doesn't apply to private practices that DON'T accept insurance at all per the language of the rule. As of now, the Trust and APA says we do all need to do this FOR CLIENTS FOR WHOME WE ARE NOT BILLING INSURANCE FOR OUR SERVICES. Finger crossed that further investigation will show that we don't have to do this at all!

    The Knowledge Tree is hosting a webinar, including their own forms, on Thursday. I think it's $15. It is hosted by Dr. Becky Beaton who is on the GPA Ethics Committee, is married to a lawyer, and who has consulted with the Trust about this already. I will definitely be attending!

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  • Julia Harris

    I would also encourage everyone to take Becky Beatons course. She will give you a document you can send out that is up to federal standards. The document can be formulated for each client, uploaded to SP, and then sent out to each individual client. The federal law requires the document to be certain length, type font size, etc. to fully comply with federal requirements. Using this template on here may not be the best idea right now until it’s brought up to standards. Just a thought!

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  • Randi Needham

     

    Do you happen to have a link to Becky's course?  I googled and went to her website, but I am not able to find anything about the course or how to register.   Thanks so much, Julia!

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  • Randi Needham

    wait I found it on another post!   Here it is.

     

    https://www.theknowledgetree.org/p/ethics-the-no-surprises-act-online/

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  • Shara Brofman

    Thanks SimplePractice for looking into this. I'm also going to attend The Knowledge Tree's seminar; another colleague had also recommended it. I wonder if another way to do this is for clinicians to generate individualized GFE forms for each patient ("read only"/downloadable), upload them securely to share them via the portal, and then create a separate, simple signature form, similar to one patients sign when they've received a Notice of Privacy Practices, indicating that they understand and agree to their individualized GFE? (That form would be identical for every patient and signable within the portal?) Otherwise, yes, it's not appropriate/doesn't make sense for patients to be filling these in.

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  • Krystal Davis

    What about the Waiver form that is required along with the GFE form? Will Simple Practice be creating a template for this that can be adjusted?

    Side note (but related) it would be SO great if assessments could be sent directly to clients through the portal instead of having to download it, upload it, then send. 

    Thanks :-)

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  • Rebecca Johnson Osei

    Thank didnt know we were required to have them sign a waiver if we are already giving them the GFE (I though a waiver would hypothetically be in place of the GFE but has not yet been confirmed to be a viable alternative).

    Re: Assessments - you can absolutely send them through the portal! That’s how we send ours. Just add them to your portal documents. Ours need to be downloaded by the client from the portal to complete, but if you have the time yo recreate it you could also feasibly make them fillable within the portal.

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  • Jennifer Anderson

    My clinicians are not able to fill in the blanks on the template with basic billing and notes role. Am I the only one that can fill in the blanks as an administrator?

     

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  • Krystal Davis

    I could easily be wrong as there are so many questions about this act but my impression was we had to have clients sign both a waiver (stating they know they can get cheaper services with in network but are choosing an out of network provider) AND the GFE as well. We also have to display some sort of notice about the Act in our offices. Curious is Simple Practice does or will be creating a Waiver form as well.

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  • Julia Harris

    Krystal - I believe the waiver you’re referring to is only for non emergency services at a facility or hospital who are in network with a patients insurance but offering them a provider who is out of network at the facility. They have to offer a waiver to a patient that the patient is aware of the situation and that someone else at the facility could see them in network but they’re choosing this. The law on the consent forms doesn’t apply to private practice out of network providers based on my understanding and every article I’ve read! The law on who can even offer these consent forms is pretty intense with lots of criteria you have to meet (and not meet). It doesn’t look like it’s just for anyone who sees any provider out of network.  But will find out more at the training tomorrow with Becky Beaton.

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  • Krystal Davis

    Thank you Julia! I appreciate the clarification. I plan on attending the training as well since I keep hearing so many things.

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  • Jennifer Valli

    I am wishing SP took more of an active role here.  We are all going in circles trying to piece info and forms together. 

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  • Serena Goldstein

    Ideally Simple Practice will create a form that will auto-import the patient's data, allow the provider to  complete the estimate section and send it via the portal, both for security and to have an electronic record for compliance.  The current form does not meet the Federal Requirements because we are unable to complete the fields before sending it. 

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  • Jenny Evans

    This template is really and truly terrible. Are you sure this is the version that is supposed to be posted?

    Nothing auto populates - we would have to type everything in by hand and to do all the math by hand... 

    Why on earth would anyone use this form? 

    I continue to be disappointed by the functionality of Simple Practice... SP always has slick design but this is a prime example of how it consistently misses the mark when it comes to practicality and user experience : ( 

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  • Sara

    Hi everyone,

    Please add feedback, comments, and suggestions to this Ideas and Suggestions Board post as this is where our Product Team will be looking for feedback on how to improve the form already created: https://simplepractice.uservoice.com/forums/918553-simplepractice-feedback/suggestions/44599761-autogenerate-good-faith-estimate

    Additionally, we have released this Pollen article covering questions that have been asked about the No Surprises Act: https://www.simplepractice.com/blog/no-surprises-act-good-faith-estimates/?fbclid=IwAR22rBOhZMwZVEWTY1fKOOI4BWpDJ5MpKafy8z915iwjwjhi9AY3KSbz1bs

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