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  1. FHIR Specification Feedback
  2. FHIR-35126

Advanced EOB Must Be A Single GFE For All Providers Instead of Multiple GFEs

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    • Icon: Change Request Change Request
    • Resolution: Not Persuasive
    • Icon: Highest Highest
    • US Da Vinci Patient Cost Transparency (PCT) (FHIR)
    • current
    • Financial Mgmt
    • STU
    • Patient Cost Transparency Implementation Guide Home Page
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      This IG is informed by the No Surprises Act, which requires that providers share GFE(s) with a payer and that a payer make an AEOB available to a patient in advance of service or upon request. Specific rulemaking on these requirements is pending. As such, the IG was written to support the flow of the necessary information from providers, to the payer, to a patient, as appropriate.

      In preparing this IG, we also evaluated the guidance CMS has provided for the related requirements for self-pay and uninsured individuals (see Requirements Related to Surprise Billing; Part II (86 FR 55980) and the subsequent FAQs released December 21, 2021 - https://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/Downloads/Guidance-Good-Faith-Estimates-FAQ.pdf). Although this is a separate use case, it is informative and helps us understand the possible approaches that could be deemed permissible regarding one or more GFEs being submitted by providers to a payer for the purposes of generating an AEOB.

      To ensure the IG supports the necessary flow of information, the IG supports one or more than one GFE being sent to a payer and one or more than one AEOB being sent to a patient. In this way, the IG can support providers and payers as they work to develop and implement a flow of information that allows them to meet the legislative and future regulatory requirement, establishing a workflow that makes most sense within their system and per their internal business operations. The IG is meant to facilitate the necessary data sharing without limiting provider and payer implementation. Should future rulemaking mandate a specific scenario, we can revise accordingly.

      It is recognized that this business challenge is significant for payers and providers and to capture those challenges openly, we encourage the community to share analysis of the significant challenge this poses for Payers and Providers here: https://chat.fhir.org/#narrow/stream/301151-Da-Vinci-PCT/topic/Sharing.20Analysis.20of.20Multiple.20GFE.20Challenge.20-.20FHIR-35126/near/275824070

      We are including the following revised language to ensure the concerns raised here are address on some level in the IG overview. This language was approved on the 8/5/2022 community call: 

      To ensure the IG supports all potential flows of information, the IG supports an AEOB being sent from the payer to the provider, in addition to a FHIR-based approach for the required flow from the payer to the patient. In this way, the IG can support providers and payers as they work to develop and implement a flow of information that allows them to meet the legislative and future regulatory requirement as well as enable information sharing valuable to supporting patient care. The IG is thus meant to facilitate the necessary data sharing without limiting provider and payer implementation options. law does not require the use of an API to share these data. This IG provides an option for how to meet the requirements of the law, but the method used to share the required information – an API, a portal, e-mail, etc. – is the decision of the parties engaged in the process. Should future rulemaking mandate a specific scenario, this IG can be revised IG accordingly.

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      This IG is informed by the No Surprises Act, which requires that providers share GFE(s) with a payer and that a payer make an AEOB available to a patient in advance of service or upon request. Specific rulemaking on these requirements is pending. As such, the IG was written to support the flow of the necessary information from providers, to the payer, to a patient, as appropriate. In preparing this IG, we also evaluated the guidance CMS has provided for the related requirements for self-pay and uninsured individuals (see Requirements Related to Surprise Billing; Part II (86 FR 55980) and the subsequent FAQs released December 21, 2021 -  https://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/Downloads/Guidance-Good-Faith-Estimates-FAQ.pdf ). Although this is a separate use case, it is informative and helps us understand the possible approaches that could be deemed permissible regarding one or more GFEs being submitted by providers to a payer for the purposes of generating an AEOB. To ensure the IG supports the necessary flow of information, the IG supports one or more than one GFE being sent to a payer and one or more than one AEOB being sent to a patient. In this way, the IG can support providers and payers as they work to develop and implement a flow of information that allows them to meet the legislative and future regulatory requirement, establishing a workflow that makes most sense within their system and per their internal business operations. The IG is meant to facilitate the necessary data sharing without limiting provider and payer implementation. Should future rulemaking mandate a specific scenario, we can revise accordingly. It is recognized that this business challenge is significant for payers and providers and to capture those challenges openly, we encourage the community to share analysis of the significant challenge this poses for Payers and Providers here:  https://chat.fhir.org/#narrow/stream/301151-Da-Vinci-PCT/topic/Sharing.20Analysis.20of.20Multiple.20GFE.20Challenge.20-.20FHIR-35126/near/275824070 We are including the following revised language to ensure the concerns raised here are address on some level in the IG overview. This language was approved on the 8/5/2022 community call:  To ensure the IG supports all potential flows of information, the IG supports an AEOB being sent from the payer to the provider, in addition to a FHIR-based approach for the required flow from the payer to the patient. In this way, the IG can support providers and payers as they work to develop and implement a flow of information that allows them to meet the legislative and future regulatory requirement as well as enable information sharing valuable to supporting patient care. The IG is thus meant to facilitate the necessary data sharing without limiting provider and payer implementation options. law does not require the use of an API to share these data. This IG provides an option for how to meet the requirements of the law, but the method used to share the required information – an API, a portal, e-mail, etc. – is the decision of the parties engaged in the process. Should future rulemaking mandate a specific scenario, this IG can be revised IG accordingly.
    • Corey Spears / Vanessa Candelora : 20-0-1

    Description

      The IG must specify a single good faith estimate (GFE) with the information for all providers involved in service rendered rather than each provider submitting individual GFEs.  This is to increase likelihood that information is complete and an accurate estimate for the member.

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            langfosl Susan Langford
            Patricia Taylor, Sam Undine (Inactive), Susan Langford
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