Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges

The Department of the Treasury, Department of Labor, and Department of Health and Human Services have issued a proposed rule related to the fees established by the No Surprises Act for the Federal independent dispute resolution (IDR) process, as established by the Consolidated Appropriations Act,2021 (CAA). This proposed rule could have implications for outpatient physical, occupational and speech therapy services for patients who are paying cash and you end up charging them more than $400 of what was listed in the Good faith Estimate (GFE) that you provided to them. In this article, I will answer the following questions:

Don’t Be Surprised Regarding the Good Faith Estimate Requirement

Rick Gawenda

The No Surprises Act was enacted as part of the Consolidated Appropriations Act, 2021, which became law on December 27, 2020. Subpart G – Protection of Uninsured or Self-Pay Individuals, does apply to outpatient physical, occupational and speech therapy services provided in all outpatient therapy settings, including private practices and does include cash-based therapy practices as well as out-of-network providers.

Don’t Be Surprised by The No Surprises Act

The Centers for Medicare and Medicaid Services (CMS) has released a new Frequently Asked Question (FAQ) document on providing good faith estimates to uninsured and self-pay patients. Disclaimer: The information below and the answers to each question are accurate as of the posting of this article (December 27, 2021). As of this posting, we have been told that Subpart G – Protection of Uninsured or Self-Pay Individuals, does apply to outpatient physical, occupational and speech therapy services provided in all settings, including private practices. The Private Practice Section (PPS) of the American Physical Therapy Association (APTA) is seeking further clarification … Read More