In the rush to figure out the Good Faith Estimate, another important issue has been on the back burner.
As you know, the No Surprises Act also had a provision that we see every patient at least once every 12 months. This was extended from the previous rule which required this provision every 6 months.
With recent guidance from CMS, it is now clear that this requirement will go into effect after the end of the Public Health Emergency (PHE). That is not likely to be before the end of 2022 at the earliest.
CSWA is hoping to work with many other mental health groups to eliminate this rule. We will keep you posted.
Laura Groshong, LICSW Clinical Social Work Association Director, Policy and Practice lwgroshong@clinicalsocialworkassociation.org
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