| Community health centers provide care to all patients, regardless of their insurance status or ability to pay for care. Health centers offer affordable services to patients using a sliding fee scale based on income, the parameters of which are laid out in the federal funding requirements for health centers. Although this structure inherently provides protections from surprise medical bills, health centers are also subject to aspects of the No Surprises Act. |
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| What is the Good Faith Estimate Rule? |
| The No Surprises Act, passed into law in 2020, is landmark legislation intended to protect patients from surprise medical bills. Surprise bills are typically the result of patients who received care but did not know the provider or facility was out-of-network. The bill is intended to prevent surprise medical bills in emergency services and out-of-network providers when the facility is in network.1 |
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| The legislation, which went into effect on January 1, 2022, includes a provision known as the Good Faith Estimate. The Good Faith Estimate rule requires health care providers, including community health centers, to provide uninsured and self-pay patients with a ‘good faith estimate' of the anticipated cost of care.2 |
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| What is included in a Good Faith Estimate? |
| Good Faith Estimates must incorporate the expected costs for primary item or service, and other items or services with a separate charge that are expected to be provided along with the primary service.3 This may include costs for an office visit and lab tests or medications. |
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| What is the timeline for implementation? |
| The Good Faith Estimate was rolled out in multiple phases, to ensure providers had time to adapt to the new requirements. Phase 1, which requires Good Faith Estimates to be for services provided in-house, went into effect on January 1, 2022. Phase 2, which requires GFEs to include care delivered by outside providers, known as “co-providers” technically also went into effect on January 1, 2022, but HHS had not been enforcing this portion of the rule. HHS delayed enforcement of this provision to allow additional time for providers to develop processes to obtain information from outside providers.4 |
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| This enforcement discretion was slated to end on January 1, 2023. However, HHS announced in early December that it would be extending enforcement discretion due to concerns about the technical capacity and feasibility of providers to obtain cost estimates from outside providers and facilities. The additional delay will allow time for advancements to be made to increase interoperability among providers.5 |
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| [1] Fact sheet No surprises: Understand your rights against surprise medical bills (2022) Centers for Medicare and Medicaid Services. Available at: https://www.cms.gov/newsroom/fact-sheets/no-surprises-understand-your-rights-against-surprise-medical-bills#:~:text=The%20No%20Surprises%20Act%20protects,network%20air%20ambulance%20service%20providers. |
| [2] Ibid. |
| [3] Frequently Asked Questions (FAQs) about Consolidated Appropriations Act, 2021 Implementation-Good Faith Estimates. (n.d) Centers for Medicare and Medicaid Services. Retrieved from https://www.cms.gov/cciio/resources/regulations-and-guidance |
| [4] FAQs About Consolidated Appropriations Act, 2021 Implementation-Good Faith Estimates (GFEs) for Uninsured (or Self-Pay) Individuals- Part 3 (2022) CMS. Centers for Medicare and Medicaid Services. Available at: https://www.cms.gov/files/document/good-faith-estimate-uninsured-self-pay-part-3.pdf. |
| [5] Ibid. |
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