As indicated in this article from January 19, the No Surprises Act—legislation designed to protect consumers against surprise medical billing in private insurance for most emergency and some instances of non-emergency care—was signed into law as part of the Consolidated Appropriations Act of 2021. This act also includes requirements that uninsured and self-pay patients receive key information, including overviews of anticipated costs and details about their rights.
Good Faith Estimate Requirement for Uninsured or Self-Pay Patients
The Academy and other interested stakeholders have received confirmation from regulators that all provider types are required to provide all self-pay, uninsured or out-of-network patients with a “good faith estimate” of the cost of care. A “good faith estimate” is defined as the best judgement of the cost of care a provider plans to provide across the episode of care. The estimate must be provided in writing, signed by the patient and included in the patient’s medical file.
If the actual patient charges are more than $400 over the “good faith estimate,” the patient has the right to challenge the bill through a dispute resolution process.
- CMS “Good Faith Estimate” Template
- CMS webpage devoted to “No Surprises Act”—including bill text and FAQs.
Academy Working with Stakeholders for Enforcement Delay and Exemption for Small Practices
The Academy, along with other stakeholders, is requesting a complete enforcement delay as well as expanded enforcement discretion for all aspects of the good faith estimate. In addition, the coalition is requesting an exemption for small practices—with 15 or fewer clinicians (see attached letter).
This legislation was implemented in a hurried fashion under an interim final rule—with limited ability for stakeholder comment. The Academy will continue to provide member updates on this topic as they become available.
The Audiology Quality Consortium (AQC), currently chaired by the Academy, submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding changes to audiology quality measures and reporting responsibilities under the Merit-Based Incentive Payment System (MIPS). The mission of the AQC is to: Collaborate on the analysis and recommendation of audiology quality measures for use in…
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Over-the-Counter (OTC) Hearing Aid Final Rule: Existing State Medical Clearance Requirements and “Prescription” Terminology
The Academy submitted a letter to the Federal Drug Administration (FDA) requesting clarification on two critical issues included in the final OTC rule to ensure the final rule can be implemented in an expeditious manner. Many state audiology licensing laws currently include a requirement that an individual receive medical clearance or sign a document waiving…