Understanding the Good Faith Estimate Requirements of the No Surprises Act: A Guide for Patient Access Staff
Dec 19
Patient access staff play a crucial role in creating a smooth and transparent healthcare experience for patients. With the implementation of the No Surprises Act, one key responsibility is to provide patients with a Good Faith Estimate (GFE) for healthcare services when required. This requirement is designed to protect patients from unexpected medical bills and to foster trust and clarity in the billing process.
In this guide, I'll break down everything you need to know about Good Faith Estimates - what they are, who they apply to, and how to incorporate them into your registration process.
In this guide, I'll break down everything you need to know about Good Faith Estimates - what they are, who they apply to, and how to incorporate them into your registration process.
What is the No Surprises Act?
The No Surprises Act, which went into effect on January 1, 2022, aims to protect patients from surprise medical bills. It includes rules for out-of-network emergency services, balance billing protections, and transparency requirements in the Good Faith Estimate provision.
The GFE provision is particularly relevant for patient access staff because it requires healthcare providers to give self-pay and uninsured patients an upfront cost estimate for services before they receive care.
The GFE provision is particularly relevant for patient access staff because it requires healthcare providers to give self-pay and uninsured patients an upfront cost estimate for services before they receive care.
What Is a Good Faith Estimate?
A Good Faith Estimate is a document that outlines the expected costs of medical services. It helps patients make informed decisions about their care by providing a clear picture of what they might owe.
Here is what is included in a GFE:
Here is what is included in a GFE:
- A description of services: A list of the services the patient is expected to receive.
- Estimated charges: The expected costs for each service, including any associated fees (e.g., facility fees, lab tests).
- Provider information: The names and contact details of all providers and facilities involved in the patient's care.
- Disclaimers: Notes explaining that the GFE is an estimate and that actual charges may vary.
Who Should Receive a Good Faith Estimate?
The GFE requirement applies to patients who are:
Important Note:
The GFE does not apply to patients who are using insurance to cover their services. However, other provisions of the No Surprises Act may still apply, such as protections against out-of-network balance billing for insured patients.
- Uninsured: Patients without health insurance.
- Self-Pay: Patients who choose to pay out-of-pocket rather than using their insurance.
Important Note:
The GFE does not apply to patients who are using insurance to cover their services. However, other provisions of the No Surprises Act may still apply, such as protections against out-of-network balance billing for insured patients.
When Should a GFE Be Provided?
You must provide a GFE:
| At least 3 days in advance | If the patient schedules service at least 10 business days in advance |
| Within 1 day | For services scheduled within 3-9 business days |
| Upon request, within 3 business days | If the patient asks for an estimate, regardless of whether or not the patient schedules an appointment |
What Should Patient Access Do?
Patient access staff are on the front lines of implementing the Good Faith Estimate process. Here is how you can ensure compliance:
1. Understand the Services Being Scheduled
When a patient schedules a procedure, gather the necessary details to create an accurate estimate. This includes:
1. Understand the Services Being Scheduled
When a patient schedules a procedure, gather the necessary details to create an accurate estimate. This includes:
- The specific services or procedures being performed.
- Any additional charges, such as lab work, imaging, or anesthesia.
- The expected duration of the service.
Pro Tip: Collaborate with your billing or revenue cycle team to ensure all components of care are included in the estimate.
What if you don't know what services or procedures will be performed?
In this situation, use your best judgement to list the most common service or procedure that is performed in your setting for the patient's condition. Remember that the GFE is an estimate, and that actual services or procedures may be different after the patient is assessed by the provider.
2. Use Tools to Generate Accurate Estimates
Many facilities use billing software or tools to generate Good Faith Estimates. However, if you are not provided with tools, an Excel spreadsheet can be used. Ensure you or your patient access staff members are trained on how to:
- Pull accurate pricing data for services.
- Account for all providers and facilities involved in the care.
- Format the GFE in a way that meets federal requirements.
Pro Tip: Always double-check the estimate for accuracy before providing it to the patient.
3. Communicate Clearly with Patients
When presenting a GFE, tone and clarity can make all the difference in the patient's experience. Here's how to approach it:
- Explain What the GFE Is: Let patients know this is an estimate, not a final bill.
- Be Transparent About Variations: Mention that actual costs may vary due to unforeseen circumstances, like complications or additional tests.
- Answer Questions: Be prepared to explain each line item and address any concerns.
Example Script:
"This Good Faith Estimate outlines the expected costs for your upcoming procedure. It's based on the information we have today, but please know the final amount may change if additional services are needed. If you have any questions, I'd be happy to go over it with you."
4. Document and Retain GFEs
Federal regulations require you to keep a copy of each GFE for at least 6 years.
Make sure you:
Make sure you:
- Document the date and time the GFE was provided to the patient.
- Save a copy in the patient's record, either electronically or as a physical document
- Ensure the document is saved in a HIPAA compliant manner.
Common Challenges and How to Overcome Them
1. Challenge: Coordinating with multiple providers for bundled services.
Solution: Work closely with schedule and billing teams to ensure all charges are included.
2. Challenge: Patients confused by disclaimers or variable costs.
Solution: Use simple, patient-friendly language when explaining the GFE.
3. Challenge: Tight turnaround times for same-week appointments.
Solution: Have pre-built templates or workflows ready for common procedures to streamline the process.
Solution: Work closely with schedule and billing teams to ensure all charges are included.
2. Challenge: Patients confused by disclaimers or variable costs.
Solution: Use simple, patient-friendly language when explaining the GFE.
3. Challenge: Tight turnaround times for same-week appointments.
Solution: Have pre-built templates or workflows ready for common procedures to streamline the process.
Why This Matters for Patients
The Good Faith Estimate isn't just about compliance - it's about trust. When patients receive a clear, upfront explanation of costs, they feel more empowered and confident about their care. This transparency reduces stress, minimizes surprise bills, and strengthens the patient-provider relationship.
Final Thoughts
Patient access staff's role in implementing the Good Faith Estimate requirements of the No Surprises Act is critical. By understanding the rules, using accurate tools, and communicating effectively, you can ensure a smoother experience for patients and maintain compliance with federal regulations.
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