What is the abbreviated good faith estimate?
The abbreviated good faith estimate (GFE) is a specific type of GFE used to comply with the No Surprises Act when dealing with uninsured or self-paying patients who won’t be charged for their care. It was created to reduce the burden on healthcare providers who don’t have the resources to provide individualized GFEs and to allow individuals to participate in the PPDR process.
A full, individualized GFE must include detailed information about the items and services, such as diagnosis codes, the facility that provides them, and the expected costs and charges. An abbreviated GFE only requires some information about the patient and the provider, the scheduled dates of the items and services, and statements and disclaimers informing that the patient will not be billed for the care received.
The information pertaining to abbreviated GFEs is found on the 2021 FAQs About Consolidated Appropriations Act. Page four specifies that full GFEs aren’t appropriate for providers who don’t expect to bill uninsured or self-pay individuals for scheduled items and services. However, they must still comply with the following GFE requirements:
- Provide an abbreviated GFE
- Not bill individuals who receive abbreviated GFEs
- Not expect payments by co-providers or co-facilities for the items and services included in the abbreviated GFE
While the abbreviated GFE can’t be found on the original 45 CFR 149.610 act, the HHS later specified it in the FAQ. Below you’ll find the necessary requirements mentioned in the document and the pertaining recommendations.
Abbreviated good faith estimate requirements
The United States Department of Health and Human Services (HHS) has established a clear guideline regarding what’s required in an abbreviated GFE. In the form itself, the provider must include the following:
- Name and date of birth of the patient
- Name, National Provider Identifier, and Taxpayer Identification Number of the healthcare provider, along with the location where the items and services are expected to be furnished
- Date(s) the items and services are scheduled for (if applicable)
- A series of disclaimers that state the rights of the patient regarding the services received, the GFE, and the possibility of starting a patient-provider dispute
The HHS also includes certain recommendations in this FAQ, with the first one being the inclusion of an email address and phone number of an authority capable of responding for the facility or provider if a billing dispute were to arise. This can be an office within the provider or an organization that’s apart from the facility, but the number and address should correspond to a person.
The second is keeping in mind that nothing in the No Surprises Act prohibits the provider from giving an individualized, complete GFE instead of an abbreviated one when dealing with self-paying or uninsured patients.
The final point in this section mentions that healthcare facilities may provide an abbreviated GFE upon an uninsured or self-paying individual's request for cost information. However, it’s specified that if the patient ends up scheduling a service or item after reading the form, a new GFE or abbreviated GFE must be provided.
Finally, providers should keep in mind that all other requirements that concern GFEs also apply to abbreviated ones. This includes timeframes, rules for changing the billed costs, and mediums for delivering the document, among other things.
Abbreviated good faith estimate template
The HHS has included example templates for both the patient/provider page and the disclaimer page. These meet all the content requirements mentioned above, and providers can use them without much modification.
Patient and provider information page
The patient and provider information page is relatively straightforward. However, accuracy is absolutely crucial for creating a valid abbreviated good faith estimate. Providers should thoroughly check the patient’s information, as errors in the details could cause delays in an eventual case of a dispute involving a third party.
Both abbreviated and full GFEs form part of the patient’s medical record, making it essential to follow all the necessary regulations. These include regulations like the HIPAA Privacy Rule.
The disclaimer template gives providers an idea of what they need to include to comply with all the requirements specified by the HSS. While the disclaimer page doesn’t have to be copied verbatim, many providers choose to keep it word-for-word due to the many disclaimer requirements established for abbreviated GFEs. We recommend using this disclaimer provided by the CMS.
Good faith estimate disclaimer requirements
An abbreviated good faith estimate must include and comply with the requirements established for full GFEs. These include the disclaimer statements that disclose the patient's rights and the information needed to start a dispute.
The above template contains all the necessary requirements, so the HHS encourages providers to use it. However, creating a personalized disclaimer page is also possible as long as it contains the following four requirements:
- A disclaimer informing individuals that the information included are only estimates for services expected to be given upon issuance of the GFE, and the actual items, services, and charges may differ from what is listed
- A disclaimer informing the patient of their right to initiate a Patient-Provider Dispute Resolution (PPDR) if the No Surprises Act is not complied with, along with information about how and where to begin the process and the assurance that it will not affect the quality of the services
- A disclaimer stating that the GFE is NOT a contract, meaning that the patient isn’t forced to obtain the items or services from any of the providers listed in the GFE
- A disclaimer stating that there may be additional items and services not reflected in the GFE that should be scheduled or requested separately (if applicable)
Abbreviated Good Faith Estimate FAQ
While the guidelines for full, individualized GFEs are clear, the abbreviated GFEs may need some clarification. Here are some common questions regarding abbreviated good faith estimates.
Is the abbreviated good faith estimate still subject to PPDR?
Yes, an abbreviated GFE is still subject to PPDR if the patient chooses to start a dispute. An uninsured or self-paying individual may start the PPDR process if they are billed $400 or more for items and services furnished on the scheduled dates. It’s essential to know that because an abbreviated GFE doesn’t specify items and services, the dispute will rule over any care provided on the scheduled date.
Abbreviated GFEs issued for cost information don't need to specify the items and services to be furnished or the scheduled date. However, if the provider doesn't issue a new GFE upon scheduling, the previous one will act as valid proof that the patient wasn't expecting to be billed. This allows them to start a PPDR process if any items or services provided after the date on the GFE issued for cost information cost $400 or more.
The HHS warns that an abbreviated GFE issued for cost information is already a commitment to not bill the patient. If the facility or provider decides to charge for any of the services or items, they must issue a new GFE to reflect the changes.
Why is there NPI and TIN on the template - is this a new requirement?
Yes, including the National Provider Identifier (NPI) and Taxpayer Identification Number (TIN) is required for issuing both abbreviated and full GFEs. The facility or provider must include this identifying information for each healthcare provider represented in the GFE.
This is detailed on page five of the 2021 FAQs About Consolidated Appropriations Act, where all the requirements are specified. Along with this, the HHS recommends including an email address and a phone number that belongs to someone within the provider’s office or organization. This way, if a dispute were to happen, the Selected Dispute Resolution Entity (SDRE) would be able to reach the provider without delay.
Is it mandatory to comply with the No Surprises Act?
Yes, it’s absolutely necessary to comply with the No Surprises Act by closely following all the guidelines imposed by the HHS. If a provider or facility doesn’t comply, it may receive a monetary sanction of up to $10,000 per violation.
The penalty's severity will depend on several factors, some of which may worsen or improve the provider’s situation. These include, but are not limited to, the following aspects:
- Degree of culpability
- Awareness of the No Surprises Act
- Impact on the affected patients
- Frequency and history of previous violations
- Current economic situation of the provider or facility
The process will be handled by state authorities if the provider or facility is in the individual or group markets in the state or offers services in the state. If the state can't provide adequate enforcement, the process will transfer to the Centers for Medicare & Medicaid Services (CMS) instead.
Automate creation and delivery of abbreviated good faith estimates with Clarity Flow
MD Clarity’s Clarity Flow is designed to simplify the process of issuing both full and abbreviated good faith estimates that comply with the No Surprises Act. Integrating seamlessly with your systems, it automates creation and delivery via mail, email, or text.
Schedule a demo today to experience firsthand how Clarity Flow can produce quick and transparent results in your revenue and workflow.