No Surprises Act

As part of the COVID relief bills passed this past year by Congress, the No Surprises Act (NSA) was passed and goes into effect on January 1, 2022. Please see the linked information to understand the full scope of the Act.

What this means for my practice is that any person who is not using or does not have in-network insurance benefits must receive a Good Faith Estimate (GFE) of how much services are expected to cost and how long they are likely to last.

These regulations were designed to prevent surprise billing in hospital emergency departments and inpatient hospital settings, but they impact all providers, myself included. It is already part of my practice that patients sign documents indicating that they have read and understood my billing policies and fee schedules, both for sessions and for missed visits, letters and consultations outside of sessions, court fees, etc. I also verbally confirm with each person that they have read and understand this information and invite questions during our first session. I make information about fees and length of treatment available on my website in the Frequently Asked Questions section.

The NSA requires a more formal written communication. As with most big changes, what it winds up looking like is likely different from what it will start off being. But based on my and my consultants’ best understanding of the law and advice from my professional organizations, I will be giving each non-insurance or out-of-network patient the form we develop via DocuSign with all information I have access to fill in.

It’s important to remember that the GFE is only an estimate. The services outlined reflect my estimate of what services may reasonably be expected to be provided to you during the estimated duration of treatment. In the course of treatment, I may recommend services that would be scheduled separately and not reflected in the initial GFE.

Because the GFE is an estimate, actual items, services, or charges may differ from what you read there.

 The Good Faith Estimate does not require you to obtain psychotherapy or any other service from me, nor does it obligate me to provide services to you. It is not a bill for services already provided.

The GFE is not a contract. It is an estimate of the total cost of treatment based on information I have available to me at the time that it is made. The fact that your fees may be more or less than those outlined in the GFE is not a “violation” of the estimate and does not constitute a breach of any kind.

As always, if you have questions about this or any other policy, please feel free to contact me!