Jane Moh • December 31, 2021

Preparing for the Good Faith Estimate


To ring in the New Year, here is a quick summary of how healthcare providers like hospitals and physician practices can develop the required workflow and resource utilization to meet the 2022 Good Faith Estimate requirements by following a few key steps.  

Providers should identify the self-pay population and services first as the rule currently only applies to uninsured patients. This can be easily performed by filtering 2021 self-pay data for the following: non-emergency self-pay patients, organize each encounter by primary HCPCS code or MS-DRG, volume based on primary HCPCS code or MS-DRG, and identify service location and involved scheduling department(s). Providers should also engage the operations leadership team by providing background information and a GFE project plan.

Once the population has been identified, then the Good Faith Estimate can be established for each self-pay service. Providers should leverage their 300 Shoppable Services from the Price Transparency regulation to help develop the GFE for self-pay patients. They can also utilize a price estimator tool to develop the GFE for all identified services. After determining the initial prices for the GFE, providers should review the gross charges and/or discounted charges for appropriateness based on historical charge data aggregation.

To implement an updated workflow, providers should develop a straw-model of future state GFE workflow and workbench. They will need to incorporate a standardize notification letter for GFE patients and the method of transmission, which can be either a hardcopy or a digital format. And, of course, all this data and new workflow must be incorporated into a staff training plan with tip sheets.

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