Quick Take: Good Faith Estimates Create Administrative Burden for Hospitals

A recent article from RevCycle Intelligence reports:

“The American Hospital Association (AHA) has asked the Centers for Medicare & Medicaid Services (CMS) to adjust the good faith estimates policy under the No Surprises Act, citing the accompanying administrative burden and operational inefficiencies as problems for hospitals and health systems.”

In their letter, AHA wrote:

“The government has substantially underestimated the burden associated with implementing the good faith estimates and patient-provider dispute resolution process,” AHA wrote. “We urge the agency to revise its estimates based on the actual experience of providers since implementation on Jan. 1, 2022. We also offer recommendations on how to minimize operational inefficiencies without compromising the policy’s important goal.”

Our Quick Take

We agree the federal government has substantially underestimated the administrative burdens associated with implementing the good faith estimates and patient-provider dispute resolution process.

Our recommended call to action:

  • Read AHA’s letter to CMS
  • Get information on the burdens associated with implementation of the good faith estimate from your organizational leadership. 
  • Contact your senators and representatives to share information on your organization’s burdens, voice your concerns, and advocate for necessary changes.
  • Contact CMS to voice your support for the AHA letter and explain how the current regulatory requirements are impacting your hospital or health care system.
Kathleen Cantwell
Director, Office of Strategic Operations and Regulatory Affairs
Centers for Medicare & Medicaid Services
7500 Security Boulevard, Room C4–26–05
Baltimore, MD 21244

Read More:

The Nuances of Operational Compliance Under the No Surprises Act: Uninsured, Self-Pay Patients

Frequently Asked Questions About Good Faith Estimates for Uninsured or Self-Pay Patients


These materials are for general informational purposes only. These materials do not, and are not intended to, constitute legal or compliance advice, and you should not act or refrain from acting based on any information provided in these materials. Neither Ensemble Health Partners, nor any of its employees, are your lawyers. Please consult with your own legal counsel or compliance professional regarding specific legal or compliance questions you have.