Current Language: Currently, there is no specific mandate dictating the Da Vinci Price Transparency IG work. Instead, this IG is informed by the No Surprises Act, which was enacted as part of the Consolidated Appropriations Act, 2021. The No Surprises Act specifically requires that providers share GFE(s) with a payer and that a payer make an AEOB available to a patient in advance of service. The initial scope of this IG was inspired by this general requirement. While rulemaking has not yet addressed how specifically this general requirement will need to be implemented, this IG is being developed to support the flow of the necessary information from providers to the payer, to a patient. Subsequent iterations of this IG or other IGs will take into consideration any relevant future regulation or legislation, as appropriate or upon request. We welcome feedback on this topic.

Comment: Suggest adding a statement here about the (optional) provision of the AEOB to the provider. This is critically important in facilitating informed conversations between providers/patients about costs; without the AEOB, the provider will have nothing to reference. We fully support the guide's inclusion of information about sending the AEOB to the provider, but it should be explained in the background section that while the law just requires the AEOB to be sent to the patient, this guide references sending it also to the provider, and this is strongly recommended for the reasons stated above.