The No Accident Law, which came into effect on January 1, 2022, requires healthcare providers to provide “good faith estimates” that cover all relevant codes and expenses. This is to increase the price transparency of patients. For the summary of the “No Accident Law”, Read our previous blog.
In our recent webinar on December 15, 2021, industry expert Stanley Nachimson, head of Nachimson Advisors*, answered the audience’s most pressing questions about “good faith estimates.” **To read the FAQ for our first webinar, click here.
This is what Natchimson had to say:
Question 1: In order to prepare for the “No Accident Act” before January 1, what is the most important thing now?
SN:
- Set up procedures to avoid out-of-network billing for emergency and in-network facility services
- Providers outside the network need to ensure that they have the correct procedures in place to avoid accidentally charging patients.
- Assess the status of all providers in and out of the network
- Implement good faith estimates for uninsured/self-financed from a single supplier
- Ensure that procedures are in place for self-paid or uninsured patients
- Prepare patient notification documents
- Train employees and make sure they understand the new rules and changes
Q2: What must be included in the integrity assessment starting on January 1, 22?
Numbering: From January 1, 2022, if only The required good faith estimate applies to patients who are “own expense” or uninsured.These are the only ones that will be enforced/enforced on January 1stYingshi.
CMS has created a table showing what should be included in the GFE. This includes the individual services that will be provided in the encounter, line item descriptions of the services, program codes, diagnostic codes, etc. Assuming there are no excuses, it is estimated that it should be within $400 of the final bill, including any providers or facilities.
Question 3: How should providers provide patients with integrity assessments? Payer?
Numbering: For patients, the integrity assessment should be provided in the form of a written document. This can be done via email, USPS or in-person delivery.
Currently, the provider does not need to worry about sending any content to the payer. Regulators will shelve this requirement indefinitely until they have a clearer understanding of the technical delivery/transformation of these data. CMS expects to clarify this ruling in 2022.
Experian Health now provides a comprehensive and updated “No Accident Act” (NSA) payer policy alert list free of charge to U.S. hospitals, medical groups, and professional healthcare service organizations.
Learn more
Question 4: Providers should consider what is the difference between the insured person and self-financed integrity estimates from January 1st?
Numbering: There may be no significant difference between the self-pay and the insured’s GFE. However, GFE will be sent to the health plan of the insured person.
At this point, there is no standard electronic delivery method. Individual providers/organizations may submit their own paper or electronic forms, assuming it contains all the necessary information. At some point in the future, GFE will be sent to the insured patient’s health plan, which is likely to be a standard transaction. CMS is currently awaiting guidance on the appearance of this transaction.
Q5: How to calculate the estimated value when multiple suppliers are involved? Who is the “convener provider”?
Numbering:
-
- The convener provider is (1) Providers responsible for arranging major projects or services(Defined as “the original reason for the visit”), or (2) receiving a request from an individual to purchase goods or services)-it must be determined at the time of arranging the goods or services or when the patient purchases care to determine whether the patient is a self-paying patient, as described above definition.
- This will not be enforced on January 1, 2022. In 2022, each provider will need to provide GFE for its own services. Since no process is in place, the healthcare industry will have at least one year to develop standard guidelines for collecting this information. The requirement to convene providers to merge all provider GFEs into one GFE will be implemented before 2023. This means that during 2022, convening providers will not need to include estimates from other providers. The industry needs to first develop standard guidelines and establish a communication process. Before that, patients need to ask all participating providers for good faith estimates. Suppliers may want to consider how they will achieve this goal in 2022.
Q6: Does the integrity assessment apply to all services-even office visits? laboratory? urgent Care? insert?
Numbering: It applies to all types of services. However, depending on the service schedule, the time range will vary based on the estimated delivery time in good faith.
Question 7: If the actual cost is more than US$400 higher than the honest estimate, what consequences will the supplier face from January 1st?
Numbering: The latest rules establish an independent dispute resolution procedure. The patient must initiate the process within 120 days of receiving the bill, submit the required documents, and pay a $25 administration fee.
Webinar Series: Unravel the “No Accident Act” and Q&A with experts
Industry expert Stanley Nachimson, a health IT implementation expert, recently hosted a series of webinars to help providers accelerate the things they need to do to comply with the No Accidents Act. Learn about integrity assessment, how NSA is applied to different care environments, etc.
On-demand webinar: Unpacking the No Accident Act
On-demand webinar: Q&A with experts
*Stanley Nachimson is not an employee or representative of Experian Health.
** The scope and details of the No Accident Law are evolving. The information provided here is current as of December 23, 2021.
This content is for informational and educational purposes only. Experian Health cannot and will not provide legal and compliance guidance. It is recommended that all organizations thoroughly review regulations and seek appropriate legal and compliance guidance to determine appropriate compliance strategies. Experian Health provides solutions throughout the healthcare process—including patient participation, revenue cycle management, identity management, care management, and analysis—that may help meet compliance requirements.
Post No Accident Act: Integrity Assessment and Expert FAQ First appeared in Healthcare blog.
