Good
Faith
Estimate
Hello Dear Clients,
In December 2020, Congress passed the No Surprises Act. It was mainly intended to reduce unexpected medical bills for patients (as example: you have surgery that is covered by your insurance & then get a huge bill from one of the providers or the facility, who are out-of-network for your plan). This law went into effect January 1, 2022. New information about this law & requirements & how they relate to private practice psychotherapists just became widely available. Our professional associations & lawmakers did not realize the implications for the variability in types of services/practices/locations/clinicians, & it seems that most of the thousands of therapists who are impacted across the country, myself included, found out about this law via Facebook or word-of-mouth!
The basics of the requirements are already in place for almost all private practice therapists, as our professional associations have strong ethical standards requiring us to:
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Inform our clients of fees before commencing treatment; &
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Make it clear that, if you have insurance, you have the option to seek a provider within your network at a lower fee; &
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Allow clients who choose to work with someone out-of-network to receive a “superbill” which can be submitted for possible partial reimbursement, depending on the policies of your individual plan (superbills also contain diagnostic codes, which are another requirement of this new bill).
Some requirements of this new legislation are expanded from the above. According to this law, we are directed to provide a diagnosis before commencing treatment (in direct contradiction with the ethical standards of our profession, which would never allow diagnosing someone without seeing them). And we are required to provide a Good Faith Estimate, to predict total costs in advance of treatment. This would make sense for something like setting a broken bone, but as you undoubtedly realize, psychotherapy does not generally work like that. We might have an idea what the trajectory of treatment for a particular issue will be, based on experiences with other clients, but we cannot know exactly what might lie beneath the tip of iceberg that initially brings someone to see a therapist, or what other concerns might arise during the course of treatment.
Like most private practice therapists, we submit charges each session, so there are no hidden costs. We can estimate length of time for certain conditions we treat (generally weekly appointments for the first 8 weeks, then continue weekly or begin to spread out to alternate weeks or more, of course depending on the individual circumstances or additional issues that may need to be addressed). To determine cost over the course of 6 months or a year, we could simply multiply the fee per session by the number of estimated sessions.
Implementation of this new law are likely to have challenges to the inclusion of psychotherapists in the way this legislation was intended. Nevertheless, the first steps we are supposed to take will be to provide you with two new forms to sign, which indicate you understand your rights:
A questionnaire to determine your insurance & claim format
A notice about Good Faith Estimates
We always try to keep paperwork to a minimum to reduce additional stress that such things tend to cause. As far as we can see at this point, none of this will impact what we actually have been doing in therapy, & we anticipate we will be able to continue without any interruptions.
I look forward to continuing to work with you & your families.
With respect & appreciation,
Tonya & The Wellness & Relational Institute Team