November 21, 2022

On November 15, APMA submitted comments to HHS, the Department of Labor, and Treasury (collectively, the Departments), and the Office of Personnel Management (OPM), in response to its Request for Information (RFI): "Advanced Explanation of Benefits (AEOB) and Good Faith Estimate (GFE) for Covered Individuals." This RFI is a continuation of the Departments' and OPM’s efforts to implement the No Surprises Act. Previously the main focus of operationalization related to uninsured or self-pay individuals.

APMA has significant concerns about the burden these proposals will have on providers if they are implemented without careful thought and input from providers about practical flow and management in their offices. APMA focused its comments on the following recommendations, among others:

• that the Departments and OPM not require an AEOB for insured patients who have not yet been evaluated by the providers;
• that an interoperable data exchange standard is needed, and agencies are urged to align requirements for AEOB and GFE data exchange with previous interoperability and patient access regulations finalized by the Office of National Coordinator for Health Information Technology (ONC) and CMS in 2020; and
• that providers are not required to coordinate and include secondary and tertiary payers’ benefits and costs for insured patients’ GFEs.

To read the comment letter in full, visit www.apma.org/CommentLetters. View all of APMA’s resources related to the No Surprises Act at www.apma.org/SurpriseBilling. If you have questions or concerns, contact the APMA Health Policy and Practice department at healthpolicy.hpp@apma.org.

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