No Surprises Act brings new billing disclosure requirements

Bottom Line: As licensed providers, psychologists must now provide estimated costs of services

Situation: Situation: With the start of the new year, the No Surprises Act went into effect. Psychologists and other health care providers are now required by law to give uninsured and self-pay patients a good faith estimate of costs for services that they offer, when scheduling care, when the patient requests an estimate, and when there are changes in estimated costs.

Background: The No Surprises Act aims to reduce the likelihood that patients may receive a “surprise” medical bill by requiring that providers inform patients of an expected charge for a service before the service is provided. The government will also soon issue regulations requiring psychologists to give good faith estimates to commercial or government insurers, when the patient has insurance and plans to use it.

Assessment: Psychologists and other providers must provide all uninsured and self-pay patients a good faith estimate of expected charges that is available in a written document that is clear, understandable, and prominently displayed, stated orally when the service is scheduled or when the patient asks about costs, and is available in accessible formats and language(s) spoken by the patient. The estimate must be provided within specified timeframes. If any information provided in the estimate changes, a new good faith estimate must be provided. 

Recommendation: Psychologists working in group practices or larger organizational settings and facilities will likely receive direction from their compliance department or lawyers. Psychologists in independent and small practices are encouraged to learn more about how to be compliant with the No Surprises Act. For more information on the No Surprises Act as well as templates for good faith estimates, see the following resources: 

American Psychological Association Services pages:
Good Faith Estimate Compliance 
FAQs No Surprise Act

Centers for Medicare and Medicaid Services Website  

Psychologists are also urged to watch out for upcoming guidance on good faith estimates to insurers. The NAN Legislative Action and Advocacy Committee (LAAC) and Professional Affairs and Information Committee (PAIC) will be monitoring how recent and upcoming changes impact our community of neuropsychologists.

The LAAC provides periodic updates to inform members about recent advocacy efforts and to request input from members about their advocacy needs. To contact the LAAC, please email us at: LAACCommittee@nanonline.org.

Fee Waiver for PsyPact E.Passport Ends January 31

Bottom Line: Initiate application for PsyPact E.passport by Jan. 31 to avoid $400 fee

Situation: The Health Resources and Services Administration (HRSA) of the US Department of Health and Human Services (HHS) has awarded ASPPB federal funding to help provide support for the 2020 Coronavirus Aid, Relief and Economic Security Act (CARES). As part of the 2020 funding, and in hopes of increasing access to mental health care services via telepsychology, ASPPB is extending the E.Passport application fee ($400) waiver until January 31, 2021. Please note that you need to have initiated the E.Passport application by January 31, 2021 to take advantage of the $400.00 fee waiver. You do not have to have your application submitted or completed by that date.

Background: PSYPACT is an interstate compact designed to allow licensed psychologists to legally and ethically practice telepsychology and conduct temporary in-person, face-to-face practice of psychology across state boundaries without necessitating that an individual become licensed in every state to practice.

States currently participating in the compact: AZ, CO, DE, GA, IL, MO, NE, NV, NH, OK, PA, TX, UT, VA; coming March 2021 NC.

States with pending legislation for inclusion in the compact: DC, IN, KY, NJ, IA, TN, WA, MN, OH, MD, CT.

Assessment: If you are licensed in a state that is part of the compact, you may want to submit an application if you are already conducting telepsychology within your home state and would like to extend your services to patients located in other compact states, or if you wish to have lower restrictions for temporary, face-to-face services in another state that has become part of the compact. Note: there are additional fees assessed, including a yearly maintenance fee for the e-passport (see PsyPact website).

Recommendation: If you are licensed in one of the compact states listed above, visit the PsyPact website today to see if you and your practice may benefit from this additional credential to allow interjurisdictional practice while the waiver is in effect (ends 1/31/2021). If you are licensed in a state with pending legislation, reach out to your state psychological association and/or your state legislatures to voice your comments about adopting PsyPact.

PsyPact Website

Application Website

The NAN Legislative Action and Advocacy Committee (LAAC) provides periodic updates to inform members about recent advocacy efforts and to request input from members about their advocacy needs. To contact the LAAC, please email us at: LAACCommittee@nanonline.org.