So far, it seems to be a bit fuzzy as to exactly what therapists ought put and where to put a Good Faith Estimate notice on their website. But with that said, the model notice shared by the CMS and the three options for how to implement the notice below are solid guesses as to what would be reasonably considered to be compliant.
The Good Faith Estimate Model Notice
The recommended notice to have on your website is the Centers for Medicare and Medicaid Services model notice. Here is the notice text in full:
You have the right to receive a “Good Faith Estimate” explaining how much your medical care will cost
Under the law, health care providers need to give patients who don’t have insurance or who are not using insurance an estimate of the bill for medical items and services.
- You have the right to receive a Good Faith Estimate for the total expected cost of any non-emergency items or services. This includes related costs like medical tests, prescription drugs, equipment, and hospital fees.
- Make sure your health care provider gives you a Good Faith Estimate in writing at least 1 business day before your medical service or item.
- You can also ask your health care provider, and any other provider you choose, for a Good Faith Estimate before you schedule an item or service.
- If you receive a bill that is at least $400 more than your Good Faith Estimate, you can dispute the bill.
- Make sure to save a copy or picture of your Good Faith Estimate.
For questions or more information about your right to a Good Faith Estimate, visit www.cms.gov/nosurprises or call [INSERT PHONE NUMBER].
Here are some edits to the notice you may wish to make
- Insert the CMS.gov phone number between the brackets: 800-985-3059
- We believe there is an error in the number of days cited in the notice and that the provision of a Good Faith Estimate should be in writing at least 3 (not 1) business days before your medical service or item.
- Generally edit the notice to be more conversational and flow better (get improved language within Empathycopy)
Where To Put The Good Faith Estimate Notice On Your Therapist Website
Option 1: In Full, Directly On The Fees Page
Copy and paste the notice directly on your “Fees” page, as far down as possible. Putting the notice further down will ensure that the most important fees information is the first information that a visitor reads. Then, lower on the page, they will also find out more about their rights to a Good Faith Estimate.
If you go with this option, it says, “no one could possibly miss the info as the full notice is on a major, relevant page of the website”
Option 2: On It’s Own Page, Linked From Fees Page
Instead of putting the entire notice on the fees page itself, you can create a new, separate page for the notice. Then, on the fees page, include one small sentence or paragraph and link to the Good Faith Estimate Notice page so that anyone wanting to read more, can.
If you go with this option, it says, “enough words about the Good Faith Estimate are included on the fees page, a major, relevant page of the website, to help a visitor click through and learn more.”
Option 3: On It’s Own Page, Linked From A Utility Menu
Create a new page with the model notice info. Then, link to it from a utility menu in the website’s footer (the small menu on websites that would also contain links to “privacy” or “terms”).
This option says, “it’s required to have it on my website so technically it is and if someone were to look for it, they could find it linked on every page.”
Which Option To Choose? For Best Results with Marketing And Sales, Go With Option 2 or 3
Although putting the full notice directly on a major page of your website is unquestionably compliant, it’s also an unfortunate distraction.
If it’s in full on a Fees page, most visitors will skip reading it entirely or start reading it, realize it’s not answering their burning questions, and then skip it.
But for a few, highly anxious, hyper-vigilant, rule-following, or perfectionistic types of incoming clients, the notice may be fully read, and fully confusing.
And unfortunately, as it’s written in the model notice isn’t very friendly. In fact, it’s kinda confusing. Questions an incoming client might have include, “Am I supposed to ask for an estimate in order to work with you?” or “should I have some system in place for tracking stuff?” or “does this even apply to me?”
There might also be confusion over some of the mentioned items that are uncommon in therapy like “equipment” or “hospital fees” leading to questions about what type of therapy you offer.
If the aim of your website is to market and sell your services, confusing website visitors may not align with what’s optimal.
If there’s a chance that the Good Faith Estimate Notice will be confusing, then avoid putting it on the fees page in full and go with linking to it instead. These alternative options where the notice is on it’s own page and either linked from smaller, friendlier amount of text on the fees page or from a utility menu would be best.
Going With The Flow
New rules to follow happen. And they happen somewhat often in the field of psychotherapy. But going with the flow of new processes to integrate and website updates to make are so much easier with help. Hope this little article helped and that you’ll find further support along the way.
(Disclaimer: nothing in this article is legal advice and is for educational purposes only. Consult with your attorney for what may be the best and most compliant option for notice text and implementation).