Premier submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to the request for information (RFI) for advanced explanation of benefits (AEOBs) and Good Faith Estimates (GFEs) for covered individuals that are required by the No Surprises Act. The RFI seeks information and recommendations on transferring data from providers and facilities to plans, issuers, and carriers; other policy approaches; and the economic impacts of implementing these requirements.
In its comments, Premier asks urged CMS and the Departments to:
- Utilize the existing claims adjudication process as a foundation for data sharing between payers and providers, rather than adopting a new Fast Healthcare Interoperability Resources (FHIR)-based application programming interface (API) solution;
- Align and streamline current price transparency programs and requirements to minimize confusion among healthcare consumers;
- Require AEOBs only for patients with scheduled care who would benefit from personalized cost-sharing estimates;
- Permit providers to access AEOBs for services they plan to provide;
- Require plans to respond to eligibility requests with procedure-specific detail to enable providers and patients to determine their insurance status for a prospective episode of care; and
- Require non-participating providers to inform payers directly through the GFE process when they have obtained patient consent to balance bill, reducing administrative burden and ensuring consistent information is included in the AEOB.