No Surprises Act & Good Faith Estimates

As a TherapyAppointment user, there's good news: we've automated most of the process within Online Forms.

Simply update our provided template and set the form to Auto-Assign to send to new clients automatically.

To learn more about this law in general and how it impacts therapists, click here

This includes:

  • When a Good Faith Estimate (or GFE) is necessary
  • Timelines for compliance
  • and the information required to be in a GFE
info On April 1st, 2022, clarifications to this law were made by CMS.
description You can read the synopsis here.

What's included in this article:


Using and Updating our Good Faith Estimate Template

To comply with this new requirement, we suggest you include a Good Faith Estimate as one of your required new client intake documents. If you don't already have one, we've created a template to make it easy, here's how:

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Log in
Required role: Owner or manager
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Access the template
  • Use our steps below to access
  • Make changes and customize it for your practice
  • Then publish, that's it!

Steps:

  • On any screen click (top right)
  • Then click Templates (top tab)
  • Find the section Online Forms
  • Click (far right):


  • Click the center button


  • In the Search field (top left) type Good
  • Under it, find the Good Faith Estimate
  • Click (bottom right within that section)
    • Prefer to see if this or any template is right for you? Click instead! You can always delete it after if you find it's not for you


  • The template should then be loaded:



  • Modify the template to match your own practice and your own fees
  • You must configure this form to comply so please thoroughly review the form and enter any necessary information (ex: type 2 NPI and TIN)
construction Learn how to edit online forms like a pro with our article here

demography Client information will be automatically filled in when the form is submitted

Their information will be pulled automatically from the client's profile. They don't have to enter anything here!

The following data will automatically load after submission:

  • Client Legal Name (First, Last)
  • Date of birth
  • Client Address



Set the online form settings:

Here we review two main settings: shared with the practice, and auto-assign.


task Shared With Practice

If this is the only Good Faith Estimate Form your practice requires, make sure it is shared with your practice. That means it will be assignable under every provider in the system.

If there are multiple providers at your group and everyone needs a specialized form, do not share this with the practice.

Note: if you are a non clinical manager or owner, by default since you are not a provider any form created by you is shared with the practice. Need provider specific forms? Have those providers 'initially create' the form with these steps and save the draft. If needed after that, an owner/manager can then further edit.

task Auto-Assign

Set this form to auto-assign, meaning every new client created under you will automatically be assigned this form. If also shared with the practice, it will go out to every client created at the group level.


Want to save a draft?

If you'd like to return back to this online form to edit and publish later, click (top right).


Want to go live?

When you're ready for this form to be either auto assigned, or available to assign to clients click (top right).


disabled_by_default Assign at Intake Without a Diagnosis/Treatment Plan

If assigning prior to meeting the client for the first time, you likely will not have a diagnosis and an expected course of treatment.


Diagnosis:

This is actually to your advantage! Simply report the diagnosis of R69 which translates as diagnosis deferred → no need for tailoring to this particular client. 


What if the referral is not for psychotherapy?

What if, for example, you are being asked to perform a standardized psychological evaluation? Then you should substitute appropriate CPT codes, descriptions, and prices for such an evaluation to the best of your ability.


Course of Treatment:

This is a Good Faith Estimate, so giving a total of an average course of therapy is sufficient for a client you have not met.

APA reports that, on average, psychotherapy lasts for 18 sessions, making this a reasonable estimate.


mail To Comply by Mail:

If you or your client prefer communication by mail, you can certainly use our template as a good starting point below:



[Your Practice Name]
Good Faith Estimate


Name: ________________________________ Date of Birth: _________________

You have been referred to my office for treatment. I’m required to give you a Good Faith Estimate of the cost of treatment if you are uninsured or don’t want to use insurance for this care. Since we haven't met, and don’t yet know if you want to use insurance for your treatment, the information below is based on “fee for service” (out of pocket) rates. 

If you DO intend to use insurance, check with your insurance carrier to find out what your copayment or coinsurance rates will be–they are likely to be much smaller. 

Since I have not yet evaluated your difficulties or symptoms, I must at this point estimate your course of treatment based upon the national average for a course of psychotherapy, which is 18 encounters. 

This initial estimate is valid for 12 months, but you are entitled to receive an update on this estimate at any time upon request.

Current ICD-10 diagnosis: R69 (diagnosis deferred).

Anticipated treatment: 

1 session of CPT 90791 (diagnostic evaluation) at [Your rates here]
17 weekly sessions of CPT 90834 (psychotherapy, 45 minutes) at [Your rates here] per session
Total of estimated "fee for services" treatment without insurance:  [Your rates here]

This is just a rough estimate based on national averages. The duration of our work together can be longer or shorter depending upon your symptoms, your work between sessions, and your response to treatment. 

Unless required by a court order (an extremely rare situation), you are free to discontinue treatment at any time, and free to discuss any other modifications to treatment modalities, frequency, or duration. You are ultimately in control of your own healthcare; I am just here to provide help at your request.

Location of treatment: All sessions will take place in my office at [Your address here/Online]

My identifying information: 

[Your name here], [Your Credentials]
National Provider Identifier: [NPI number here]
Tax ID Number: [Tax ID number here] (do not provide your social security number if you are using this for your practice's Tax ID Number)

This information should not be constituted as legal advice. Information surrounding compliance of the No Surprises Act is vague at this point. If you have questions about compliance and regulations, please visit CMS.gov or speak to your practice's attorney.