Can I provide a single good faith estimate to a patient who I anticipate treating throughout the year?
Yes. If you expect to provide a recurring service to the uninsured/self-pay patient, you are allowed to submit a single good faith estimate to that patient for those services, so long as: (1) the good faith estimate includes, in a clear and understandable manner, the “expected scope of the recurring primary items or services (such as timeframes, frequency, and total number of recurring items or services)”; and (2) the good faith estimate can only include recurring services that are expected to be provided within the next 12 months. For additional recurrences beyond 12 months, the provider must provide a new good faith estimate and communicate any changes between the initial and the new estimates.
For example, if you have a psychotherapy patient that you expect will need continuing therapy throughout the year, the good faith estimate might say the following:
I expect that my care of you will require continued weekly therapy sessions continuing through the end of the year, at $X per session for a total of 50 weeks, accounting for vacations and holidays for an estimated total of [$X x 50].
Or if the future course of treatment is less certain, an estimate might look like this:
Depending on the progress we make this year, I expect that you will need 10–20 more sessions this year. At $X per session the estimated total cost would be [10X–20X].
I provide services in a setting offering multiple kinds of services to the same patient (i.e., a federally qualified health center, rural health clinic, hospital), and I do not separately schedule appointments or bill for my services. Does this rule apply to me?
The regulation describes slightly different obligations for a “convening provider or convening facility,” which is a provider or facility who receives the patient’s request for a good faith estimate of costs and is responsible for scheduling the primary item or service.
Depending on how appointment requests are received and scheduled in your setting, psychologists who work at these types of facilities might not be responsible for compiling or providing the good faith estimate, but they are expected to contribute any information that may be relevant to the estimate.
If you are in such a setting, you should consult with your facility or clinic’s compliance officer or attorney about your personal obligations under this new regulation.
My patient is insured and intends to use their insurance to pay for my services. How do I send this information to the patient’s insurance plan?
Federal agencies will soon issue rules specifying the form, timing, and manner by which good faith estimates must be transmitted to insurers. APA will provide further updates when these rules are issued. The information in this FAQ is only meant to apply to communication with patients who are self-pay or uninsured.