This notice serves to address the new federal “no surprises” act that was enacted on 1/1/22 and clarify how it relates to the practice of psychology. All healthcare providers are now required to notify clients of their federal rights and protections against “surprise billing.” It requires that we notify you of your federally protected rights to receive a notification when services are rendered by an out-of-network provider, if a client is uninsured, or if a client elects not to use their insurance.
The act was developed in response to situations where patients receive unexpected charges for medical procedures. For example, some hospitalized patients found that providers involved in their direct care did not participate with their insurance. Even though they had no control over who treated them while in the hospital, they were nonetheless held responsible for charges that they never authorized.
The “No Surprises” act should be very helpful in such situations and protect vulnerable patients. It carries the expectation that all potential services should be outlined ahead of time. The broad sweep of this act, though, encompasses outpatient healthcare providers and out-of-network psychologists who provide individual services, and where unexpected charges rarely occur. It presumes that clients may encounter unexplained charges throughout the course of psychotherapy. It also presumes that psychologists can accurately predict each client’s long-term cost of treatment. Both assumptions are not relevant to most outpatient psychotherapy practices.
I am required to provide you with a Good Faith Estimate of the cost of services since I am not in-network with any insurance companies. Psychotherapy consists of individual appointments – not a service involving multiple providers, or a “package” limited to a set number of sessions. Most people enter psychotherapy quite aware that neither they nor the therapist can clearly predict how many sessions will be needed. My philosophy is anchored in honoring each client’s choices and goals along the way. Although I may offer my professional recommendations related to the benefits of weekly sessions or when fewer sessions are needed, I always leave it up to the client to decide when they wish to decrease the frequency of sessions or stop therapy.
I am including this information on my website, as now required by law, but with the awareness that it is not reflective of my practice as a psychologist. I am always clear about my fees, and clients who work with me accept my decision to not participate with health insurance plans. I understand that some prospective clients find the cost prohibitive, and I completely respect that. It is always your choice whether you prefer to work with a therapist who is in-network or out-of-network. (See more about my decision to not participate in insurance plans here.) If you choose to work with me, please know that I will never "surprise" you with an unexpected bill.
The document below is a standardized form explaining some of the information in the No Surprises Act. Please note that the information about this act and how it applies to the practice of psychology is unclear, and most professional organizations associated with psychology and legal experts are still parsing through the law to understand how to best implement it. Please accept this information with the knowledge that what is listed here may change over time. When it does, I will update it. As always, if you have any questions, please let me know!
(OMB Control Number: 0938-1401)
The purpose of this document is to let new and current clients know about your protections from unexpected medical bills. I am required by Federal Law to provide this information to you. (Please note that some portions of this document have been modified to better reflect this provider's practice of psychology.)
You are receiving this notice because this provider or facility does not participate in insurance plans, and therefore, is not in your health plan’s network. This means the provider or facility does not have an agreement with your insurance plan.
Receiving care from this provider or facility could cost you more.
If your plan covers the item or service you are receiving, federal law protects you from higher bills:
· When you get emergency care from out-of-network providers and facilities, or
· When an out-of-network provider treats you at an in-network hospital or ambulatory surgical center without your knowledge or consent.
Ask your health care provider or patient advocate if you need help determining if these protections apply to you.
This law reminds you that you may pay more because:
· You are giving up some protections under the law associated with in-network health insurance practices.
· You will owe the full costs billed for items and services received.
· Your health plan might not count any of the amount you pay towards your deductible and out- of-pocket limit. Contact your health plan for more information.
If you are working with this provider, you will be asked to sign a form agreeing to accept the provider's fees for out-of-network treatment. Please sign this form only if you feel that you have a choice in selecting providers. You should not sign this form if you did not have a choice of providers when receiving care (for example, if a doctor was assigned to you with no opportunity to make a change.)
Before deciding whether to sign this form, you have the option of contacting your health plan to find an in-network provider or facility. If no one is available, your health plan might work out an agreement with this provider or facility, or with another one. (Please note: this provider is under no obligation to accept any agreement with your health insurance plan.)
You also will receive a Good Faith Estimate of costs regarding what you will be expected to pay. This includes the following information:
Total cost estimate of what you may be asked to pay: It is your right to determine your goals for treatment and how long you would like to remain in therapy unless you are pursuing mandatory treatment. The total number of sessions you may require cannot be predicted, and it would be unethical for this provider to predict long-term costs of services, since as the patient, you determine how long you will continue in therapy. You will be provided a breakdown of all possible fees on the Good Faith Estimate. From there, you can identify the service you will receive (for example., one hour of psychotherapy). The total fee for treatment services over time will be the number of sessions you receive multiplied by the ongoing session fee. The estimate does not include any information about what your health plan may cover or how much they may reimburse you for services. This means that the final cost of services may be different from this estimate. Contact your health plan to find out how much, if any, your plan will pay.
Please review your detailed estimate once you receive it.
Call your health plan. Your plan may have better information about how much of these services are reimbursable.
Questions about this notice and estimate? Call this provider at 215 884-9260
Prior authorization or other care management limitations
Except in an emergency, your health plan may require prior authorization (or other limitations) for certain items and services. This means you may need your plan’s approval that it will cover an item or service before you receive them. If prior authorization is required, ask your health plan about what information is necessary to receive coverage. (Note: it is unlikely that prior authorization is required for out-of-network services; however, you still may wish to contact your insurance plan about this.)
More information about your rights and protections
Visit https://www.cms.gov/files/document/model-disclosure-notice-patient-protections-against-surprise-billing-providers-facilities-health.pdf for more information about your rights under federal law.