CMS delays enforcement of combined Good Faith Estimate requirement

December 13, 2022

Last week, the Centers for Medicare & Medicaid Services (CMS) released new guidance extending an enforcement delay of the uninsured/self-pay good faith estimate convening provider requirements until further rulemaking to establish a standard technology or transaction. Previous guidance had indicated that effective January 1, 2023, a “convening” provider would need to provide a combined estimate including all providers and facilities involved in the care. That is extraordinarily difficult when services are provided by different entities. The new guidance delays enforcement of the requirement anticipating development of application programming interface (API) for this purpose.

At this time, the estimates only need to include the expected costs for the items and services provided by the primary provider or facility. However, the estimates will eventually need to include the expected costs from all providers and facilities involved in the health care event. The convening provider, defined as the provider or facility responsible for scheduling the primary item or service, will eventually be responsible for coordinating with the co-providers and co-facilities to create the comprehensive good faith estimate. (Andrew Busz,


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