No Surprises Act

As your liability insurance carrier, the Preferra Insurance Company RRG, our risk management emphasis is to help avoid adverse regulatory enforcement. When it comes to how to fit a regulatory effort into your practice, we’ll work to share resources on the topic prepared by social work experts.

What is the best way to avoid allegations of a federal or state regulation violation?

Follow the law. The best way to start this process is to research the regulation, make points on how to fit the requirements of the law as a consistent part of your client care delivery.

What is the “No Surprises Act”?

It is a federal law for healthcare providers to give uninsured and self-pay patients a good faith estimate (GFE) of costs for services starting on January 1, 2022. In addition, GFE’s will be required for health insurers by providers, when the patient has insurance and plans to use it.

Why was this law created?

The goal is to reduce the likelihood that patients may receive a “surprise” medical bill by requiring that providers inform patients of an expected charge for a service before the service is provided.

What professions and services will need to comply with this law?

According to CMS guidance, any health care provider acting within the scope of the provider’s license or certification under applicable state law. This includes social workers, no specific specialties or types of service are exempt.

What should a Good Faith Estimate (GFE) include?

The National Association of Social Workers (NASW) has unpacked the tools for compliance on GFE’s. The law requires a very specific list of identifying information that can be found in the professional content shared by NASW under the “Compliance Steps” section of this recent blog post:

Remember, this is an estimate. In short, the Good Faith Estimate should:

• Outline professional service fees;
• A potential range of sessions that may be needed;
• Estimate costs at the end of each range; and
• Factors that may influence whether costs ultimately land toward the lower or higher end of the range.

As I work to deliver this information to my clients, are there any deadlines to be aware of?

Yes. Delivery of a GFE has a specific timeline to review in advance that is available in the social work content link above. Delivery and updates on GFE’s cannot be an afterthought.

As I work to include the “No Surprises Act” into my practice, is there more information to help guide my efforts?

• National Association of Social Workers Topic Information:
  https://www.socialworkblog.org/practice-and-professional-development/practice/2021/12/federal-rule-to-prevent-surprise-health-care-billing/
• Centers for Medicaid and Medicare Services (CMS):
  https://www.cms.gov/nosurprises
• Health and Human Services:
  https://www.hhs.gov/about/news/2021/11/22/new-hhs-report-highlights-how-no-surprises-act-will-prevent-surprise-medical-bills-faced-millions-americans.html

Any additional questions? Contact our Preferra Plan Administrator to request a risk management hotline call at 888-278-0038.