6 Things SLPs Should Know About the No Surprises Act Good Faith Estimate

good faith estimate no surprises act speech-language pathologist

First, understand the No Surprises Act is still going through changes. It was enacted Jan 1, 2022 with limited clarity to many providers. Within the No Surprises Act, there is the requirement of a Good Faith Estimate (GFE), which many therapists across various private practice settings have found challenging. I’m here to tell you:  The consequences of this act are only activated when you provide surprise bills!

It seems simple to say, but it is actually as simple as that. If you are providing evaluation and treatment, make sure your client knows the cost of those services long before the visit. This is best practice. The golden rule still applies: Treat others how you want to be treated. Wouldn’t you prefer to know all possible costs before a doctor’s visit?

1.  For speech-language pathologists, the Good Faith Estimate can be as simple as continuing to notify your clients of your private pay rate.

The No Surprises Act requires some additional language, but best practice should be to inform your clients of your rates in writing and capture their acknowledgment before serving them. How far in advance should this be done?

2. Provide at least 72 hours notice of your rates.

This law standardly requires advanced notice, but if the appointment is made the same day, 3-hours notice is adequate.

3. Failure to provide adequate notice limits patient-participation costs.

If you or anyone in your practice is out-of-network and you fail to provide your patient with a Good Faith Estimate, their maximum out of pocket costs will be limited to their in-network rates.

4. Private pay practices are not absolved from providing a Good Faith Estimate.

Though it’s pretty clear a private pay practice would have provided a transparent statement of the costs of services, this law’s placement encourages you to also capture the client’s signature stating awareness.

5. This law is currently written for providers to offer Good Faith Estimates to clients who are out-of-network or uninsured.

Read that statement again and consider this: What happens if your insured client loses coverage? This is the reason why I highly recommend providers offer everyone in their practice a Good Faith Estimate. Additionally, this law will eventually apply to insured clients in the near future.

6. The patient must actually receive a surprise bill for your practice to be out of compliance.

Remembering this law will soon apply to patients with insurance, it’s in your best interest to understand how to vet your patient’s insurance policies with high accuracy. As the law is written, if you underestimate by $400 or more and surprise bill your client, your practice can now be reported and fined for violating the law.

ASHA has also compiled What You Should Know About the No Surprises Act and they’ve also provided a Good Faith Estimate template for SLPs.


Note: ASHA’s good faith estimate template is only a model. It does not dictate which services should or should not be listed on the estimate and does not imply medical necessity. All procedures, billing codes, or other pertinent information are not included in the model.

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