Practice Management

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  • 1.  No Surprises Act Disclosure Notice Agreement with Hospitals

    Posted 02-06-2023 14:32
    Does anyone have an agreement with a hospital in which they have entered into regarding the hospital's providing the NSA Disclosure Notice to patients on the radiology group's behalf?  We're having trouble getting one in place with our hospitals.

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    Leigh Wright RHIA
    Compliance & Privacy Officer
    The Radiology Clinic, LLC
    Tuscaloosa AL
    (205) 343-0904
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  • 2.  RE: No Surprises Act Disclosure Notice Agreement with Hospitals

    Posted 02-06-2023 15:40

    Hi Leigh

     

    Here are the instructions from the Model Disclosure Notice:

     

    Public Disclosure Requirements

    The disclosure notice must be publicly available, and (if applicable) posted on a provider's or facility's public website.

     

    - To satisfy the public disclosure requirement, providers and facilities must prominently display a sign with the required disclosure information in a location of the provider or facility, such as, where individuals schedule care, check-in for appointments, or pay bills, unless the provider doesn't have a publicly accessible location.

    - To satisfy the separate requirement to post the disclosure on a public website, the disclosure or a link to the disclosure must appear on a searchable homepage of the provider's or facility's public website.

     

    So, unless your group has a publicly accessible location where your people have contact with patients within the hospital, I don't think it would be required for the hospital to distribute your disclosure notice.  We're a hospital-based group and we just posted it in our website.

     

    Hope this helps.

     

    Dave

     

           David Smith, FACMPE  |  Executive Director  |  913.444.9359

    5800 Foxridge Dr.  Ste 240  |  Mission, KS  66202  |  www.uickc.com

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  • 3.  RE: No Surprises Act Disclosure Notice Agreement with Hospitals

    Posted 02-07-2023 09:32
    Thank you, David.  We do have an imaging center, where patients come for imaging as well as to pay their bills, including hospital bills, so we do have the notice posted and on our website.  We are just trying to work out an agreement with the hospitals so that we don't send duplicate notices to those patients. 

    Notices to Patients
    • Effective January 1, 2022
    • Scope:
    o Facilities (generally hospitals and freestanding ED's) and providers who render services
    to Facility patients, including hospital-based radiology groups
    • Requirements:
    o Facilities and providers must provide a one-page notice to patients explaining their
    protections under the No Surprises Act
     Must be posted on websites
     Must be posted in facilities
     Must be handed to patients
    o In lieu of handing multiple notices to patients covering the facility and each provider,
    facilities may hand a single notice to patients covering both the facility and providers,
    provided there is a written agreement to do so in place between the facility and
    providers

    2022 RBMA Guide to the No Surprises Act Page 5 of 7

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    Leigh Wright RHIA
    Compliance & Privacy Officer
    The Radiology Clinic, LLC
    Tuscaloosa AL
    (205) 343-0904
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