“No Surprises Act” – NOTICE


“No Surprises Act”

Dear Current And Potential Future Clients,

Congress enacted a “No Surprises Act” that went into effect 1/1/2022. The act is described as “new federal protections against surprise medical bills that take effect in 2022. Surprise medical bills arise when insured consumers inadvertently receive care from out-of-network hospitals, doctors, or other providers they did not choose” (please see https://www.kff.org/health-reform/issue-brief/no-surprises-act-implementation-what-to-expect-in-2022/).

It is highly unlikely this could affect our work together. There will be no situation in which you would “inadvertently” receive care from me or with no choice. The work we do together is done with full informed consent. Also, final rules about how to implement this in a practice such as mine have not been clarified. I am “out of network” for all but two insurance companies, one of which is Medicare, which has extensive protections for beneficiaries, including the fact that I can never accept more than the amount they allow. You may read more about this at https://www.cms.gov/nosurprises.

If you’d like to get an idea what the “interim final rules” look like that we’re all being asked to understand and implement, take a look at this: https://www.federalregister.gov/documents/2021/10/07/2021-21441/requirements-related-to-surprise-billing-part-ii.

If we currently work together, you are already aware of my charges and your costs. If you are considering working with me, available information suggests I might need to provide you with a diagnosis before we even meet, which of course would be both unethical and impossible without a meaningful evaluation of your circumstances. It’s even possible you may not have a “mental health diagnosis.”

Many professional organizations have worked to understand the details of this law, to whom it applies and how to apply it. Guidance is uncertain and in some cases conflicting. Indeed one of the main professional organizations with which I’m affiliated – the American Psychological Association – along with ten other mental health-focused professional associations – has filed objections to the supposed requirements of this law as these affect mental health practices. You may view those objections here: https://www.apaservices.org/advocacy/no-surprises-act-letter.pdf.

Rest assured that I will be as transparent as possible with you about the costs of the services we agree on together. You will have “no surprises” here. This transparency is required by ethical standards by which I have abided for the 32 years I have been in practice, and simply because it is necessary for us to work well together.

In the meantime, you may certainly ask me about any costs about which you may be unsure, and you will be provided clear information.

Please feel free to contact me if you have any related questions. My contact information is available under the OFFICE LOCATION/CONTACT menu on this website.

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