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CMS Issues FAQs on Surprise Billing, Good Faith Estimates

Two new Centers for Medicare & Medicaid Services documents answer FAQ about No Surprises Act (NSA) rules for health care providers and provision of good faith estimates (GFEs) for uninsured or self-pay patients.

The FAQ for providers include common concerns about NSA rules and guidance on patient signature requirements, independent dispute resolution fees, and exceptions to the following requirements:

  • balance billing for out-of-network emergency services;
  • notice and consent;
  • disclosure of patient protections;
  • GFEs for uninsured or self-pay patients; and
  • continuity of care when a provider’s network status changes.

The FAQ on GFEs clarify requirements for including diagnostic codes for initial visits and expected charges for future visits. They also outline instances when GFEs are not required, including:

  • for recurring visits;
  • when unforeseen services are provided;
  • for walk-in appointments; and
  • if the patient was insured when the appointment was scheduled but is not insured at the time of the appointment, unless the provider is notified three business days before the appointment.

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


About the Author

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

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