Effective January 1, 2022, the No Surprises Act was introduced as part of the Public Health Service Act of 2021. This law aims to protect individuals from unexpected medical bills for emergency services provided by out-of-network facilities, or for individuals who are uninsured, self-paying, or not seeking reimbursement through insurance at in-network facilities. Under the No Surprises Act, clients are only responsible for in-network cost-sharing amounts. Additionally, uninsured clients are entitled to a good faith estimate of care costs.
Overview
Surprise billing occurs when clients unknowingly receive services from out-of-network providers, leading to higher medical costs than if the services had been provided by in-network providers. This can happen when a provider involved in your care is not in your health plan’s network. The No Surprises Act is designed to reduce these unexpected charges by requiring out-of-network providers to give clear, advanced notice about their network status and cost estimates, ensuring you are not caught off guard by higher costs.
Consumer Notice
A key component of the No Surprises Act is the requirement for out-of-network providers to inform clients about their network status before services are provided by providing a Good Faith Estimate (GFE).
The GFE is an estimate of the expected costs for health care items and services, based on your anticipated needs, diagnosis, and the reason for your mental health care services. The estimate is created using the information available at the time and reflects the expected charges for scheduled treatments. However, it does not include any unexpected or unforeseen costs that may arise during your treatment. If complications or special circumstances occur, the cost may be higher than initially estimated, and a new GFE will be provided to you.
If the costs change and you have not been notified with an updated GFE, federal law allows you to dispute (appeal) the bill, provided you and your provider have not discussed the change beforehand.
Important Note: The GFE requirements do not apply to individuals who are using insurance benefits (including “out-of-network” benefits) or are submitting superbills to insurance for reimbursement.
We provide a standard notice that informs clients when out-of-network services are being provided. This notice will be given within 70 hours of a scheduled appointment or 3 hours for same-day services. The notice will include:
- A statement that the provider or facility is out-of-network
- A good faith estimate of the cost of services
This document will be separate from other documents you may sign before receiving care, and it can be provided in both paper and electronic formats, as per your preference.
You are never required to forgo your protections under the No Surprises Act. You also have the option to choose an in-network provider or facility.
Below is a list of frequently provided services that you may see listed on your GFE:
- 90791: Initial Psychotherapy intake (not timed)
- 90792/99205: Initial Psychiatric Intake (not timed)
- 90834: Individual therapy appointments (approximately 38-45 minutes)
- 90837: Individual therapy appointments (approximately 53-60 minutes)
- 90847: Family/Couples appointments (approximately 45-60 minutes)
- 90853: Group Psychotherapy (typically 90-120 minutes)
- 99213: Psychiatric Follow-Up appointments (approximately 10-15 minutes)
- 99214: Psychiatric Follow-Up appointments (approximately 20-30 minutes)
- 99215: Psychiatric Follow-Up appointments (approximately 20-60 minutes)
- 90833/90836: Psychotherapy Add-On to Psychiatric Appointments
- 96132: Neuropsychological Testing & Evaluation (first hour)
Below is a list of frequently used diagnoses that you may see listed on your GFE:
- Adjustment Disorder (F43.23)
- ADHD (F90.09)
- Mental Disorder, Not Otherwise Specified (F99)
- Depression (F32.9)
- Anxiety (F41.1)
- Bipolar Disorder (F31.9)
- Posttraumatic Stress Disorder (F43.10)
- Obsessive-Compulsive Disorder (F42.2)
- Borderline Personality Disorder (F60.3)
Each individual’s mental health treatment is unique and personalized. The duration and frequency of your sessions will be influenced by a variety of factors. A new GFE will be provided if necessitated by a change in your treatment needs.
If You Have Concerns or Questions
If you believe you have been incorrectly billed or are unsure whether the No Surprises Act applies to your situation, or if you have any questions regarding the notice forms, please contact us at:
Aspect Counseling & Psychiatry
Phone: (804) 796-0790
Email: info@aspectcounseling.com
Filing a Complaint
If you still believe you have been wrongly billed, you may file a complaint with the Centers for Medicare & Medicaid Services (CMS) at www.cms.gov/nosurprises/consumers or call 800-985-3059.