FAH Hospital Policy Blog

Perspectives on health policy affecting America's hospitals and the patients we serve.

Sarah Aillon

FAH Comments on Surprise Billing RFI

Today the FAH submitted comments to the Departments of the Treasury, Labor, and Health and Human Services (HHS) (collectively the Departments) regarding their Request for Information, Advanced Explanation of Benefits (AEOBs) and Good Faith Estimate (GFE) for Covered Individuals (RFI). This RFI seeks public comment as the Departments develop implementing regulations for AEOBs and GFEs as required under the No Surprises Act. FAH comments provide key recommendations related to implementation of the AEOB and GFE requirements in a manner that is streamlined, standardized, automated, and minimizes regulatory burdens by coordinating with existing processes and requirements and adopting national standards and processes that will be deemed compliant. The comments highlight that approaches that necessitate manual communication of GFE information among facilities and providers or require non-standardized and non-automated GFE submissions to payers would impose undue burden on providers and facilities and unnecessarily risk the provision of inaccurate or incomplete information. Likewise, failing to coordinate the GFE processes with payers’ processes for obtaining prior authorization and/or verifying eligibility and coverage would create improper burdens on providers and create inaccurate and confusing AEOBs that provide cost-sharing information without any assurance of coverage.

You can read the entire comment letter here.