You Got to Have Faith – No Surprises Act Review of Good Faith Estimates

EqualizeRCM is hosting a Critical Access Hospital (CAH) Forum – Nothing to Fear About Surprise Billing on February 24, 2022. This is in response to the No Surprises Act that was passed at the beginning of this year.

If you have ever received care at a healthcare facility, then you may have been surprised to find out that some providers are not in-network with your insurance. The No Surprises Act was passed to address these scenarios for self-pay, uninsured, and insured patients that are out-of-network.

Effective January 1, 2022, patients must receive a good faith estimate within three days of service (unless it is emergent). A summary of the requirements are below:

  1. Post notices concerning an “uninsured (self-pay)” patient’s right to a good faith estimate at the provider’s offices and on the website.
  2. When someone seeks care, determine if the patient is considered self-pay.
  3. Let self-pay patients know orally and in writing that they have the right to request a good faith estimate of charges, or upon scheduling an appointment.
  4. Give a written good faith estimate within the No Surprises Act. Details are below:
    1. If the item or service is scheduled at least three business days before the date the item or service is scheduled to be furnished: not later than one business day after the date of scheduling;
    2. If the item or service is scheduled at least 10 business days before such item or service is scheduled to be furnished: not later than three business days after the date of scheduling; or
    3. If a good faith estimate is requested by a self-pay patient, or if a patient asks about the cost of care: not later than three business days after the date of the request.[1]

However, there are some limits on providing the good faith estimate. HHS seems to indicate some items or services may not be included in a good faith estimate. This is due to the nature of the service that is not typically going to be requested for a good faith estimate (i.e., urgent, trauma, or emergency services). HHS mentions that if an urgent care appointment is scheduled at least three days in advance, these interim final rules would require providers and facilities to provide a good faith estimate.

You may ask, what if a hospital or group does not comply with these requirements? States have the primary responsibility for enforcing the rules under the No Surprises Act. If the state does not substantially enforce the No Surprises Act, then HHS can impose a corrective action plan and/or civil monetary penalties of up to $10,000 per violation. (No Surprises Act § 2799B-4(a)-(b), 42 USC § 300gg-134(a)-(b); 45 CFR §§ 150.101(b)(3), 150.501(a), and 150.513(a)).

To learn more about the No Surprises Act, go to EqualizeRCM is here to help you think through these complexities on February 24, 2022 at 11:00 a.m. CST. We invite all Critical Access Hospital CEOs and CFOs to join us at the CAH Forum, where we will dive into the details about surprise billing. To sign up, go to


  1. § 149.610 Requirements for provision of good faith estimates of expected charges for uninsured (or self-pay) individuals – Requirements of providers and facilities (45 CFR § 149.610(b)(1)). Retrieved from

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