“The AAFP is deeply concerned that once implemented, the AEOB requirements will add a much greater level of administrative burden and further reduce staff time spent on patient care,” the letter warned. of November. “In addition to being inconsistent with the spirit of the no-surprises law, the AEOB’s primary care requirements are likely to confuse and frustrate patients.
“Before seeing the patient, it will be extremely difficult for the practice to make a reasonable decision about the patient’s condition or any tests, treatments, referrals or other services that may be needed,” the Academy added. “Requiring practices to generate the GFE will force them to guess, resulting in an inaccurate or irrelevant AEOB being sent to the patient, undermining the overall purpose of the AEOB requirements.”
Citing the Medical Group Management Association’s most recent report on regulatory burden, in which 90% of respondents expressed concern about the complexities arising from AEOB requirements, the AAFP called on regulators to
- exempt from the rule preventive services that individual, group and self-insured health plans are required to cover without cost-sharing under the Patient Protection and Affordable Care Act;
- provide an exception where the patient chooses to opt out of receiving an AEOB;
- let primary care practices issue one GFE per year (resulting in a single AEOB for patients) “for ongoing longitudinal primary care services, including those related to the monitoring and treatment of chronic conditions” as well as for conditions acute or other care requiring recurring appointments with a primary care physician;
- not impose deadlines on practices to generate GFEs and transmit them to insurers;
- requiring health insurers to send a patient’s AEOB to the medical practice that submitted the GFE information for that AEOB; and
- allow primary care practices to provide an abbreviated GFE/AEOB for new patients or when the relevant diagnostic and procedure codes cannot reasonably be determined.
These abbreviated GFEs/AEOBs, the letter adds, would include a range of expected fees but would not include diagnostic or procedure codes. “This will reduce the risk of GFE requirements causing delays in care, address unnecessary and inappropriate burden on patients and administrative staff, and result in a more positive patient experience,” the Academy wrote.
The AAFP also highlighted technical challenges it said regulators should address before implementing the AEOB requirements in any healthcare setting, including
- the absence of an existing standard to effectively transmit GFE and AEOB information between practices, payers and patients;
- application programming interfaces based on rapid healthcare interoperability resources which, the letter warned, are “insufficiently mature for the real-time exchange of healthcare data”; and
- unclear regulations governing how insurers separate data systems and teams processing GFE and AEOB data from other insurer functions.
The letter called for a pause on AEOB requirements until rapid healthcare interoperability resource standards are “developed, thoroughly tested in real-world settings, and ready for use by practices.” medical”.
“Action is needed to ensure that health insurers will use the GFE/AEOB data they receive responsibly,” the Academy added. “The AAFP strongly encourages departments to explore other safeguards to protect patient health information and the patient-physician relationship.”
HHS recently said it would delay enforcement of certain provisions of the GFE that were scheduled to begin January 1, 2023, “pending the development of future rules.” The AAFP continues to advocate for new measures.
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