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CMS Urged to Address Provider Concerns in GFE Process

Analysis  |  By Amanda Norris  
   June 08, 2022

The American Medical Group Association (AMGA) raised concerns about the good faith estimate (GFE) process and how it is creating an administrative burden for medical groups.

In a letter to CMS, AMGA members said GFE requirements have resulted in significant challenges for providers to effectively schedule, coordinate, and deliver care.

AMGA members report completing more than 45,000 GFEs in a month and expect that number will increase, according to the association.

"The current GFE requirements impose additional stress to an already strained healthcare workforce," said AMGA president and CEO Jerry Penso. "CMS should reform the process so that the estimates provide the information patients need without creating new administrative obstacles for providers to overcome."

The AMGA says it applauds HHS' efforts to promote transparency but believes there is a misunderstanding as to the infrastructure needed to satisfy GFE requirements in a timely matter.

In the letter, AMGA members say their concerns stem from three key areas:

  • Unclear guidance: Guidelines issued to providers are either confusing or conflicting, and providers have raised questions about the circumstances necessitating the delivery of a GFE to a patient
  • Staffing constraints: AMGA members report that non-medical staff are required to allocate a significant number of hours to complete GFEs
  • Cost and infrastructure barriers: AMGA members report a significant expense associated with completing GFEs

In line with the cost and infrastructure barriers, the AGMA says there is currently no realistic way to complete GFEs electronically.

"Members are developing workflows and infrastructure to support GFEs, but doing so diverts scarce resources from other priorities, particularly during the ongoing public health emergency. This includes reassigning staff from other duties to complete GFEs," the letter says.

The AMGA recommends that CMS work with stakeholders to develop a process in which GFEs are beneficial for patients, while not causing additional administrative burdens to providers.

Amanda Norris is the Associate Content Manager of Finance, Payer, Revenue Cycle, and Strategy for HealthLeaders.


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