Good Faith Estimate - What to do after Jan 1, 2022

Providers should view the uninsured GFE requirement as the first step in new federal regulations on healthcare providers. Even once a provider is compliant with the GFE requirement, there will be continual work required to make sure their compliance does not lapse. Two things providers can do is to monitor their GFE workflow and stay apprised of Federal regulations and CMS updates that may affect their billing practices.  

Once a provider has identified their self-pay population, the prices for all identified services, and integrated the workflow into their daily operations, they should think about monitoring the GFE workflow efficiency and GFE accuracy.  To identify and track potential issues, providers should look at their self-pay volumes, services (HCPCS codes or MS-DRGs) and service locations to make sure they are consistent with prior data. Providers can also compile patient feedback as an important data source. Lastly, providers can monitor and analyze the difference in charges between the GFE and captured charges, which should have a variance of $400 or less . These monitoring activities will tell providers the frequency of charge disputes and if any additional training is needed for the staff.

To maintain compliance with GFE requirements, providers should be able to update the GFE at time of service. They should also identify and organize their co-provider list and coordinate with co-providers on obtaining their GFE. Lastly, they should monitor CMS regs to stay up to date on any changes to these requirements.