Good Faith Estimates

Congress enacted the No Surprises Act (NSA) in 2020 to protect patients from so-called “surprise” medical bills that result from receiving care from an out-of-network provider without knowing beforehand, particularly in emergency situations. The NSA requires that all healthcare providers (professionals and facilities) provide uninsured or out-of-network patients with a Good Faith Estimate (GFE) of the cost of care prior to furnishing it. See the resources below to assist in developing and providing these estimates.

ASRS Business of Retina GFE Presentation

CMS Resources

Disputed Surprise Bills: The NSA also implemented an independent dispute resolution (IDR) process to mediate reimbursement negotiations between providers and payers when out-of-network care occurs. This provision has perhaps drawn the most attention, but it is unlikely that retina specialists will provide emergency care to patients without being able to provide a GFE or even that the total cost of the professional services would reach the minimum threshold amount to trigger the IDR. Additional information on the IDR is available on the CMS website.

If you need assistance, please contact Allison Madson, Vice President of Health Policy, at