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CMS Issues FAQ on Surprise Billing Good Faith Estimates for Uninsured

The Centers for Medicare & Medicaid Services (CMS) on Dec. 21 issued an FAQ document on requirements for good faith estimates (GFEs) for the uninsured under surprise billing part II regulations.

The requirements outlined in the FAQ document begin on Jan. 1, 2022. In general, regardless of the amount or type of discount, all financial assistance should be reflected in the GFE. Providers with financial assistance policy requirements must apply any expected discounts to the GFE. CMS states all uninsured patients with no expected financial responsibility or those who receive a set price for scheduled services should be offered a GFE because the actual billed charges are not guaranteed. CMS also noted that under the No Surprises Act statute, providers are not required to offer Medicare and Medicaid beneficiaries a GFE.

CMS acknowledges it will take time for providers and facilities to develop systems and processes for receiving and providing required GFE information from co-providers and co-facilities. Through Dec. 31, 2022, the agency will exercise enforcement discretion in situations in which a GFE is provided to an uninsured or self-pay individual without the expected charges from co-providers or co-facilities. But nothing prohibits a co-provider or co-facility from providing the GFE information before that time.

The FAQ document also describes:

  • which providers are required to provide GFEs to uninsured individuals;
  • GFEs requirements for self-pay patients;
  • GFE formats; and
  • GFE requirements of co-providers and co-facilities.

Earlier this month, America’s Essential Hospitals submitted concerns regarding many of these topics.

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions


About the Author

Julie Kozminski is a policy manager at America's Essential Hospitals.

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