Surprised by the No Surprises Act?

 Written by Kelsey Someliana-Lauer, Virtual Assistant with Therapy Practice Solutions 



Were you surprised by the announcement of the No Surprises Act going into effect in January of 2022?  Were you even more startled to find out self-pay or private-pay mental health clinicians (in other words, those that see clients who are not insured or under-insured and charge them for services) were subject to abiding by this law?  Have no fear, Therapy Practice Solutions is here! - to provide you with tips on how to not fret over Good Faith Estimates under the No Surprises Act.


What is the No Surprises Act?

The No Surprises Act is a policy “aimed to protect consumers, excessive out-of-pocket costs are restricted, and emergency services must continue to be covered without any prior authorization, and regardless of whether or not a provider or facility is in-network” (https://www.cms.gov/nosurprises/Ending-Surprise-Medical-Bills). Whew - what does that mean? This act is simply saying consumers should know how much they’re expected to spend on treatment, and have a right to dispute the bill if it’s much higher than expected.  To prevent this, a Good Faith Estimate is provided shortly after scheduling to inform the client of their anticipated cost.


What is a Good Faith Estimate?

A Good Faith Estimate (GFE) is a statement provided to a consumer giving them your best estimate of how much your services will cost.  This should be available in a written document that the client may keep for their records (and you should keep a copy, too!).  The goal of a Good Faith Estimate is to give clients the most accurate estimate of service costs you can over their anticipated span of treatment - this should include cost per session of course, but also a list of late cancellation or no-show fees, emergency services fees, fees for documentation requests, or any other fees you may tack on at your practice.  


What Do I Need to Include on My GFE?

For out-of-network mental health practitioners, here is the basics of what a GFE should feature:


  • Patient demographics such as legal name and date of birth

  • What kind of service is provided to the client (we suggest including not only descriptions of psychotherapy, but stating possible emergency services, documentation completion, case management, or whatever else you may charge for)

  • A list of services that may be provided to the client (we suggest including your rates for your most commonly billed services, such as 90837s (60 minute psychotherapy), 90834s (45 minute psychotherapy), and 90832s (30 minute psychotherapy) as a minimum).

  • Appropriate diagnosis codes (we’ll talk about this more later!)

  • Length of treatment (we’ll ALSO talk about this later!)

  • Your business information (business name, Tax ID, NPI I, and name of rendering provider)

  • Services that may need separate scheduling (see above under kind of service provided!)

  • Four disclaimers - (1) there may be additional services not listed here rendered, (2) that the GFE is only an estimate, (3) that clients are allowed to dispute their bill if it’s significantly higher than their GFE + instructions on how to do that, and (4) that the GFE does not constitute a contract and clients aren’t obligated to receive all or any of the services listed on it


If I Haven’t Provided Services to a Client, How Do I Know Length of Treatment or Diagnosis?

Here’s a common question - you haven’t yet met with a client, but you’re expected to provide a diagnosis.  What gives?!

One of our best suggestions is to provide the diagnosis code R69 to denote a deferred diagnosis, or a diagnosis that will be given later on.  Note this “diagnosis” is not covered by many insurances, so you’ll want to deliver an appropriate diagnosis after seeing the client and adjust as necessary.

For length of treatment, we suggest to follow best practice of estimating 1 visit per week, 52 weeks a year.  Chances are, the client will not actually attend 52 sessions in one year given cancellations, sickness, and holidays; this ensures your estimate should go above and beyond their actual services.  


Are There Templates for the GFE?

Sure there are!  There are multiple templates you can utilize for the GFE.  Here are a few we like:

APA's GFE Template

CMS's Disclosures (not a full GFE)

Additionally, if you use an online practice and record-keeping resource like Theranest or SimplePractice, they have their own versions in their online libraries you can download as well.  Check out the “Help” section of your EHR to find out how to download their version of the GFE!


Hopefully this has helped clear up some confusion regarding implementing the GFE in your practice.  Remember - all clients, whether established or new, will need their own GFE and to be informed of their rights if you are a private pay clinician.  If you need help uploading templates, entering information, or sending out GFEs to clients, hire a Virtual Assistant.  Therapy Practice Solutions Assistants are abreast of new insurance billing and legal compliance trends like the GFE; let us help you!  Fill out a contact form here if you’re interested in seeing what we can do.

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