There is good news regarding the requirements for CHCs to provide Good Faith Estimates (GFEs) to uninsured and self-pay patients. From a practical perspective, the requirement that CHCs include costs for services provided by non-CHC providers in the GFEs they give to uninsured and self-pay patients is on hold indefinitely per an FAQ released by CMS on Dec. 2. The FAQ acknowledges that providers will need adequate time for implementation for new regulatory requirements. CMS stated that it would delay enforcing the Phase Two requirements until it finalizes a regulation implementing those requirements. Providers are still waiting for a new regulation or FAQ for CHCs and other providers that use sliding fee scales. To indicate how long they would delay enforcing the legal deadlines, CMS broke the GFE rules into three phases.
- Phase One: GFEs must be provided: Only to uninsured and “self-pay” patients, and only include costs for services/items that are provided and billed directly by the CHC.
- Phase Two: GFEs for uninsured and self-pay patients must also include costs for services/ items that the patient receives from outside (non-CHC) providers during an “episode of care” that is coordinated by the CHC.
- Phase Three: GFEs must be provided to patients who plan to bill their insurance.