The No Surprises Act Support and Resources
We know that the specifics of how to provide the GFEs for self-pay clients have generated a lot of questions and some understandable anxiety within the practicing community.
We have addressed the No Surprises Act and GFE specifics a number of times in both of our direct support and consultation forums, Office Hours and Group Practice Office Hours, and Liath has been conferring with Eric Ström, JD PhD LMHC, who joins in facilitating the Group Practice Office Hours sessions with the PCT consulting team once a month since we addressed it in our last joint session.
We have not created our own template form for the GFE yet. Eric and Liath are considering doing a training or creating some material resources around it as more information and guidance becomes available now that it is in effect. However, our wonderful friend and colleague, Barbara Griswold LMFT of Navigating the Insurance Maze, just released a clarifying article and a free template GFE form last week.
Another option is provided from one of our clients — and a future PCT CE presenter — Dr. Tara Sanderson, who graciously shared the GFE form she created + the signature acknowledgment page via PCT’s Group Practice Care Facebook group — with the intent of it being an option for colleagues to use as a template starting point for their own GFE. Are you a group practice leader and not yet a part of the Group Practice Care Facebook Group? Join here.
In addition, there are templates from the good folks at the APA for both the Good Faith Estimate and the Notice of Right to Receive a Good Faith Estimate (such notice must be prominently included on your practice website.)
We do advise — as risk management folks who subscribe to the “documentation or it wasn’t done” mantra that follows from the HIPAA regulators and can be applied to most every instance of considering how to follow regulation in practice — that you do obtain a signature from the client confirming receipt of the GFE (like Tara’s template provides for.)
Opportunity to Advocate:
Amend the No Surprises Act of 2022 regarding Private Practice Mental Health Clinicians. Sign the petition