ALERT: No Surprises Act brings new billing disclosure requirements 

Bottom Line: As licensed providers, psychologists must now provide estimated costs of services. 

Situation: With the start of the new year, the No Surprises Act went into effect. Psychologists and other health care providers are now required by law to give uninsured and self-pay patients a good faith estimate of costs for services that they offer, when scheduling care, when the patient requests an estimate, and when there are changes in estimated costs.

Background: The No Surprises Act aims to reduce the likelihood that patients may receive a “surprise” medical bill by requiring that providers inform patients of an expected charge for a service before the service is provided. The government will also soon issue regulations requiring psychologists to give good faith estimates to commercial or government insurers, when the patient has insurance and plans to use it.

Assessment: Psychologists and other providers must provide all uninsured and self-pay patients a good faith estimate of expected charges that is available in a written document that is clear, understandable, and prominently displayed, stated orally when the service is scheduled or when the patient asks about costs, and is available in accessible formats and language(s) spoken by the patient. The estimate must be provided within specified timeframes. If any information provided in the estimate changes, a new good faith estimate must be provided. 

Recommendation: Psychologists working in group practices or larger organizational settings and facilities will likely receive direction from their compliance department or lawyers. Psychologists in independent and small practices are encouraged to learn more about how to be compliant with the No Surprises Act. For more information on the No Surprises Act as well as templates for good faith estimates, see the following resources: 

American Psychological Association Services:

Centers for Medicare and Medicaid Services:

Psychologists are also urged to watch out for upcoming guidance on good faith estimates to insurers. The NAN Legislative Action and Advocacy Committee (LAAC) and Professional Affairs and Information Committee (PAIC) will be monitoring how recent and upcoming changes impact our community of neuropsychologists.

The LAAC provides periodic updates to inform members about recent advocacy efforts and to request input from members about their advocacy needs. To contact the LAAC, please email us at: