clinical social work association

I want to call your attention to a new rule from CMS that will go into effect on January 1, 2022.  This rule requires us to give a “good faith estimate” (GFE) to a patient of what our services will cost and how long they may last.  While this policy is part of most of our informed consent forms, signed by the patient already, it is prudent to review what the GFE is more formally requesting we include in our information to the patient about the course of their treatment.  The main difference about past practices and the GFE is that it applies to private pay patients as well as uninsured patients.

There is a CMS template for providing this information which can be found at good faith estimate (PDF, 130KB) . However, this 8-page document is more applicable to hospital stays and procedures.  It may be more helpful for LCSWs to make sure they have the following information in their informed consent or verbally transmitted and documented.

Here is a list of what belongs in the GFE (which can also be part of an informed consent or disclosure statement) for private practitioners:

• The patient’s name and date of birth;
• A description of the psychotherapy or other service(s) being furnished to the patient;
• An itemized list of items or services that are “reasonably expected” to be furnished;
• Expected charges associated with each psychotherapy session or other service(s);
• Your name, National Provider Identifier, Tax Identification Number, office location where services will be provided;
• A disclaimer that there may be additional items or services that you recommend as part of the treatment that will be scheduled separately and are not reflected in the good faith estimate;
• A disclaimer that the information provided in the good faith estimate is only an estimate and that actual items, services, or charges may differ from the good faith estimate; and
• A disclaimer that the good faith estimate does not require the private pay patient to obtain psychotherapy or other services from you.

This information can be transmitted orally but should be given to the patient as soon as possible. For ongoing patients, there should be a new informed consent or GTE statement provided with the information above.  CSWA will provide a template for this shortly.

Laura Groshong, LICSW, Director, Policy and Practice  
Clinical Social Work Association  
lwgroshong@clinicalsocialworkassociation.org