At the end of 2020, Congress passed an omnibus bill called the Consolidated Appropriations Act of 2021, which included the No Surprises Act, legislation designed to provide federal protection against surprise medical bills. On 9/30/21, a rule implementing the new law was passed that substantially impacted counselors, especially those providing therapy for private pay, uninsured, and out-of-network clients. That rule became effective 1/1/22, yet few counselors are knowledgeable about the new law’s requirements, let alone how to implement them.
Among other requirements, the act obligates clinical mental health counselors (CMHCs) to:
• Ask clients whether they have insurance and, if so, whether they want to use their insurance to fund their therapy.
• Inform all private pay and uninsured clients (regardless of whether they were already working with the CMHC prior to 1/1/22 or not) that a “good faith estimate” is available (in the client’s spoken language) and is “prominently displayed.”
• Provide to all private pay and uninsured clients a “good faith estimate” including all anticipated services and costs and several other components outlined by the Centers for Medicare and Medicaid Services (CMS) within one business day (if the service is scheduled at least three business in advance) or within three business days (if the service is scheduled at least 10 business days in advance or a client requests an estimate but has not yet scheduled the appointment).
Confused about these new requirements and how to implement them? As a service to our membership, the Florida Mental Health Counselors Association (FMHCA) provided a complimentary 1-hour webinar providing an overview of the new rules and resources for complying with the new law.
The handouts referenced in this webinar can be accessed at nortonconsulting.box.com/v/No....
Disclaimer: This video was posted for educational purposes. The presenter's perspective is not a substitute for sound legal advice from an attorney. The presenter recommends that any practitioner seeking legal guidance for implementation of the act consult with an attorney.