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Now Is the Time to Shape Future Good Faith Estimate Rulemaking

Analysis  |  By Amanda Norris  
   September 20, 2022

The departments of the Treasury, Labor, and Health and Human Services released a request for information regarding the No Surprises Act.

The departments recently released a lengthy request for information for revenue cycle leaders to inform future rulemaking to implement advanced explanation of benefits (AEOB) and good faith estimate (GFE) requirements under the No Surprises Act.

The request asks commenters to share their expertise on a range of issues and even poses specific questions to help inform the development of future regulations. Some of these questions include:

  • What issues should the departments and office of personnel management (OPM) consider as they weigh policies to encourage the use of a fast healthcare interoperability resources-based application programming interfaces (API) for the real-time exchange of AEOB and GFE data?
  • What privacy concerns does the transfer of AEOB and GFE data raise, considering these transfers would list the individual’s scheduled (or requested) item or service, including the expected billing and diagnostic codes for that item or service?
  • How could updates to this program support the ability of providers to exchange GFE information with plans, issuers, and carriers or support alignment between the exchange of GFE information and the other processes providers may engage in involving the exchange of clinical and administrative data, such as electronic prior authorization?
  • What, if any, burdens or barriers would be encountered by small, rural, or other providers, facilities, plans, issuers, and carriers in complying with industry-wide standards-based API technology requirements for the exchange of AEOB and GFE data?

Comments are due in 60 days and electronic comments on this regulation can be submitted on its website.

Amanda Norris is the Revenue Cycle Editor for HealthLeaders.


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