The American Medical Association (AMA) is 'deeply concerned' by MedPAC's recent report recommendation and says it would 'imperil' patient access and quality care.
Following the release of MedPAC's March report to Congress, the AMA urged Congress to revise the Medicare Physician Fee Schedule (MPFS) to include stable, annual payment updates that keep up with inflation and practice costs.
In a letter to congressional leaders, the AMA stated that it is "deeply concerned" by MedPAC's recommendation to continue the freeze in Medicare physician payments in 2023 despite rising inflation in medical practices, statutory payment cuts to physicians, and fiscal uncertainties related to the COVID-19 pandemic.
Overall payment to Medicare physicians has decreased 20% from 2001–2021, when rates are adjusted for inflation, according to data from the advisory committee.
The AMA says this will influence provider organizations' patient experience, as the costs to practice medicine would "imperil patient access to high-quality care."
The medical association also cited a 2021 JAMA study, which says it costs an organization an estimated $12,811 and more than 200 hours per physician per year to comply with CMS' Medicare Merit-Based Incentive Payment system. "Most physicians still have not had opportunities to transition to value-based Medicare Advanced Alternative Payment Models (AAPM), as Congress intended, and have not been eligible for the annual incentive payments for AAPM participants," the AMA said.
The AMA also claims that the payment freeze is impossible to justify when viewed against a projected 8% payment increase for Medicare Advantage plans in 2023.
Related: CMS Cuts Medicare Payments to Docs, Extends Telehealth Payments
Leaders at Hutchinson Clinic share their experiences on outsourcing revenue cycle management processes to ensure the success of the organization.
Running an effective revenue cycle is no easy feat. That is why leaders at Hutchinson Clinic in Hutchinson, Kansas, knew they had to outsource some of its revenue cycle processes to ensure the success of their organization.
There are many areas within the revenue cycle that benefit from being streamlined, from better patient access to less coding denials, but one area of focus that is becoming more common is the need to reduce accounts receivable days in the billing department. Outstanding accounts receivable in healthcare are one of the most critical issues for an organization as they affect a hospital's bottom line.
Common benchmarks for accounts receivable days in healthcare include:
High performing: 30 days or less
Average performing: 40 to 50 days
Below average: 60 days or more
As the accounts receivable days for Hutchinson Clinic were hovering around average, Mike Heck, CEO, and Dashun Monk, CFO, knew the organization needed to reduce these days and rework the management of denied claims, among other inefficiencies, in order to prosper.
After brainstorming, their team realized that having an experienced, outsourced group of professionals working behind-the-scenes to handle the complexities of revenue cycle management was the missing piece that Hutchinson Clinic needed.
Heck and Monk recently spoke about their journey as leaders at the largest multispecialty clinic in Kansas and the three lessons they learned in enlisting a third party to help with its revenue cycle management.
Lesson 1: Realize the need for revenue cycle management expertise
Hutchinson Clinic is home to 535 employees, 63 physicians, 95 providers, and over 30 outpatient specialties. These include specialty ancillary services such as an ambulatory surgery center, physical therapy, radiology/diagnostic imaging, endoscopy center, and dietitian services.
Despite a culture at Hutchinson Clinic known for its convenience and patient satisfaction, there remained one lingering problem: a lack of an experienced revenue cycle management team that could ensure that basic financial responsibilities were being met efficiently and correctly.
In 2018, after a year of research and extensive interviews with third-party vendors, Heck and Hutchinson Clinic's board of directors brought on CareCloud (the parent company of Meridian Medical Management) to help with a variety of deliverables, including:
Accounts receivable follow-up
Charge entry
Claims coding
Denial feedback on coding
Patient posting
Physician education
"To me, it came down to leadership," Heck said. "We needed the right level and technical ability of leaders in the revenue cycle management arena. We couldn't establish consistency before they came on board."
Once Hutchinson Clinic's new revenue cycle management team ramped up, the positive results were seen fairly quickly across the board.
"Aside from the fact that we have drastically improved the financial stability of accounts receivable, the biggest benefit that I didn't foresee has been the ability to apply a larger trained workforce to certain projects," Heck said.
In addition to outsourcing an experienced and robust staff, Hutchinson Clinic introduced a healthcare analytics and business intelligence platform. The technology is used to manage data across the organization, which in turn, closes care gaps, increases revenue, and improves overall workflow within the organization.
Lesson 2: Keep patient experience in the forefront
While having an experienced partner was one piece of the puzzle, equally important to the Hutchinson Clinic team was the ability to find which methods worked the best for the organization internally, while still working to improve the patient experience.
The clinic has a team of roughly 60 in-house revenue cycle management employees who needed onboarding and training before all processes could be improved. At the same time, Heck was adamant that this process didn't disrupt continuity of care for the patients stretched across Hutchinson's large geographic footprint.
"The beauty of working with a partner like this is that they're handing all of the heavy lifting behind the scenes, enabling us to focus on patient engagement, provider recruitment, and retention," Heck said. "We've recently seen a positive response from the community as a result."
Being that Hutchinson Clinic is the primary source of care for those in Reno County, it's imperative that patient engagement is at the head.
"We see quality care and patient satisfaction as our number one responsibility," Heck said. "Having a stable revenue cycle management ensures that bills are getting out the door and payments are being made, which frees our team up to focus on other areas."
Echoed Monk, "I have peace of mind knowing that our revenue cycle, specifically the coding, accounts receivable, and posting components are happening correctly and in an efficient manner."
Lesson 3: Listen to staff and community stakeholders
Making an important change in revenue cycle management has a large effect on everyone involved with an organization, and one thing Hutchinson Clinic says it has gained through this experience is the importance of knowing their audience. In the case of its current partnership, the audience is twofold: the staff and the patients in the community.
Letting staff and patients know that you are listening to their questions and concerns when implementing a large change such as outsourcing is any easy way to help aid in a positive transition.
"We didn't want to sacrifice what was important to us and our community," Heck said. "When we're talking to our physicians about their pain points, such as coding or compensation, it's important for them to know we're listening. Same goes for the patients—we need to be making their lives easier, not harder."
Seeing results
While bringing in a third-party vendor isn't viable for every organization, Heck and Monk say there are takeaways that can be applied from their experience to help other health system executives accomplish their goals. These include:
Identify gaps. Every organization has areas they want to improve (e.g., reducing number of accounts receivable days, increasing cash flow).
Ask for help. "Find a subject matter expert on revenue cycle management and don't be afraid to ask tough questions," Monk said.
Change takes time. "It took us a year to identify a solution for outsourcing our revenue cycle management needs. It also takes time for a new partner to learn your language. Don't rush the process," Heck said.
Since outsourcing its revenue cycle management processes, Hutchinson Clinic has seen a reduction in accounts receivable days from 38 days to 33 days, thus shortening the time it receives payments from the insurance carriers. This five-day improvement of accounts receivable days is a 15% improvement for the organization. On top of this, the aged accounts receivable days of greater than 120 days has been reduced by 3% at Hutchinson Clinic.
"The processes put in place before outsourcing weren't moving us in the right direction," said Monk. "Today, we're meeting industry standards in terms of reducing accounts receivable days, ensuring doctor's compensation, and the efficient reworking of denied claims."
Industry leaders offer insight into management styles that have changed as revenue cycle staff is now more remote.
The COVID-19 pandemic has caused many organizations to shift staff to remote work over the last couple of years. Revenue cycle departments are no exception.
The National Association of Healthcare Revenue Integrity recently conducted an industry survey which included a variety of revenue cycle leaders. All respondents reported that their department's current work environment is now either completely remote (47%) or hybrid (53%).
Forty percent of respondents reported changes to their annual review processes or management strategies, processes, and policies.
Among the changes reported were the implementation of new productivity measures, adjustments to work hours to address time zone differences, and the development of new goals and goal-setting processes.
According to the survey, the implementation of productivity measures was the most frequently reported change. Such measures included daily and weekly electronic reports, more frequent personal communication between managers and staff, and daily meetings to discuss accomplishments.
"A hybrid model is preferred in our department," says Sevenikar. "Working from home is a privilege that is performance-based."
Dennis Shirley, vice president of revenue cycle at UnityPoint Health in Des Moines, Iowa, agrees that allowing your revenue cycle staff to work from home requires a focus on performance.
"Having remote staff has required a revamp of structure for productivity and managing our teams," Shirley said.
Sevenikar says she likes the idea of a hybrid work environment for her revenue cycle department because when working remotely, the knowledge transfer that happens when you are co-located can be lost. This, Sevenikar says, can create a huge disconnect.
To this point, Shirley adds that "when it comes to educating teams, you lose those collision points that your employees would have gotten from being at the office."
To alleviate these issues, it's important for revenue cycle leaders to routinely engage directors, managers, and other staff to create a sense of community.
"This feeling of being disconnected is not ideal for the workforce. In addition to daily huddles, I have a weekly, all-staff call to remedy this. There are almost 1,000 people that report to me across the enterprise and they are all invited to join the call. We discuss department updates, organizational updates, successes, questions, and just chat. We need to connect with our employees on what is important to them," says Sevenikar.
UnityPoint Health has done everything from sending out monthly newsletters for trainings, updates, and culture, to setting up coffee and lunch chats to manufacture that sense of community.
"Putting the focus on quality and productivity tracking, as well as manufacturing this culture, has been instrumental to our staff being remote," Shirley said. "Supervisors that monitor quality allow for the carving out of educational and personable leaders."
When revenue cycle teams are working remotely, it's more important than ever to recognize an employee's success and achievements, Sevenikar notes.
"We meet in a huddle and share an employee story. This helps to let them know I see them and so do their coworkers. This creates a sense of appreciation that dominos into feelings of trust and achievement," says Sevenikar. "Getting personal with your employees creates a culture of love and appreciation that will help to retain your staff."
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The Centers for Disease Control and Prevention (CDC) and CMS released new ICD-10-CM diagnosis codes and ICD-10-PCS procedure codes for use on claims submitted on or after April 1.
The new ICD-10-CM codes are used by the revenue cycle's coding team to report patients who are unvaccinated for COVID-19, partially vaccinated for COVID-19, and other underimmunization status.
The new ICD-10-PCS codes will be used to report certain COVID-19 vaccines and boosters, the administration of fostamatinib (an oral spleen tyrosine kinase inhibitor used to treat adults with low platelet count due to chronic immune thrombocytopenia), and certain monoclonal antibodies.
In the April 1 code update, the CDC also made available a Tabular List and Alphabetic Index addendum, Official Guidelines for Coding and Reporting update, ICD-10-CM order file, and finalized list of codes and descriptions.
In March 2021, the ICD-10 Coordination and Maintenance Committee announced it was considering an annual ICD-10-CM/PCS code update for April 1 in addition to the October 1 update. In the fiscal year 2022 IPPS final rule, the additional annual implementation date of April 1 was officially adopted.
The coding department is one of the most critical parts of the revenue cycle. Because coding occurs mid-cycle, it provides an opportunity to catch mistakes introduced earlier in the process, as well as preventing similar errors in the future.
Staying abreast of these regulatory coding updates is important for revenue cycle leaders as coding—and its completeness and accuracy—has a profound impact on an organization's bottom line.
Revenue cycle leaders scramble to fill roles in various stages of the revenue cycle process.
Healthcare leaders ranked the roles within the revenue cycle where they most need talent in a new survey released by AKASA.
The survey, which includes the responses from 400 healthcare financial leaders, ranked registrars, billing specialists, and patient follow-up staff as the most in-demand positions within the revenue cycle.
These revenue cycle roles followed closely behind:
Front-office staff
Central scheduling
Denial specialists
Authorization staff
Claims specialists
Collections
"We're seeing staffing gaps at every stage of the revenue cycle process," Amy Raymond, vice president of revenue cycle operations at AKASA, said in a press release.
"Revenue cycle departments are essential to the success of a healthcare organization," Raymond said. "When there's a demand, revenue cycle specialists are hired. When there's less demand, they're let go. This reactionary hiring cycle results in permanent workers often facing too much work and patients having a less-than-stellar financial experience."
The healthcare field has lost an estimated 20% of its workforce over the past two years , and hiring for those large staffing gaps has proven difficult for revenue cycle leaders.
Carlos Bohorquez, CFO at El Camino Health in Mountain View, California, told HealthLeaders that there was already a staffing shortage at his organization before the pandemic, and that forces each worker to put in a bit more effort.
But when the pandemic hit, and many healthcare workers were forced to do double shifts or work without days off, some quickly reevaluated their commitment to the profession. Then, as staff started quitting, things got especially bad.
Alicia Auman, director of patient access at KSB Hospital in Dixon, Illinois, is well aware of the need for registrars within in the revenue cycle and has worked diligently to improve staff retention.
"We developed a tiered pay scale. People who check in patients are paid in tier one. Once you have training and you've been in the department for a while, you can move into pre-registration, and you would get a bump in your pay. You're growing; we trust you with more and more responsibility. Tier three would be the authorization team and financial counseling," Auman told HealthLeaders.
"Since we implemented all of this, the staff satisfaction and our retention has gone up. Turnover was reduced by 42% to 25% in two years.
"These people need to know how to do this job. It's not just checking in patients; it's not just creating an encounter. There's important information that you need to get up front. We have changed that mindset in doing a career ladder.
"It was awesome because I wanted to show people that you can come in to access. Don't think of it as an entry-level position; think of it as an opportunity to build your skill set … you can go on to do something different in the revenue cycle. … It opens their eyes [that] there's a career path within healthcare that's not clinical."
A recent study meant to reflect price transparency compliance shows that organizations' cash prices are often lower than payer-negotiated rates.
Discounted cash prices for common hospital services were often lower than the payer-negotiated rates for the same services, according to a recent study published by theJournal of the American Medical Association.
According to the study, "the more expensive services were less likely to be disclosed, which might suggest strategic disclosing decisions. Some hospitals set their cash price comparable to or lower than their commercial-negotiated price."
The authors of the study said their findings contradicted their expectations as they expected the cash price to be more costly than negotiated commercial prices.
For example, the study found that 38.4% of hospitals had cash prices below their median negotiated commercial prices for liver function tests. Similarly, 68.5% of hospitals in the study set cash prices below their median negotiated commercial price for cesarean deliveries.
Though the study was released to reflect compliance with the price transparency law, it found that compliance remains inconsistent since only 922 of the 5,395 hospitals studied disclosed both their cash and commercial negotiated prices in 2021.
Once more organizations disclose prices to comply with the price transparency rule, the cross-hospital variation of cash prices will likely increase, the study said.
Just a few days after the January 1, 2021, compliance deadline for the price transparency law, Becky Greenfield, a partner with Wolfe Pincavage, told the HealthLeaders' Revenue Cycle Podcast that none of the hospitals she had investigated were fully compliant with the rule yet.
Not much changed as the year progressed. In February 2021, a Guidehouse analysis found that roughly 30% of hospitals weren't compliant with either requirement of the CMS price transparency rule, and only 48% of hospitals were compliant with at least one element of the machine-readable file requirement.
Most recently, a February 2022 study published by PatientRightsAdvocate.org showed that only 14% of hospitals are fully complying with CMS' price transparency rule even though we are now in year two of the legal requirement.
Revenue cycle leaders at the University of Utah Health successfully established an automated and streamlined audit process that identifies potential errors at the point of coding.
It's no secret that a streamlined auditing process can optimize an organization's revenue cycle and increase reimbursement. And while implementing an automated auditing process can benefit most departments within the revenue cycle, a great place to start is within the middle revenue cycle: coding.
HealthLeaders spoke with Gail Draper, revenue integrity director at the University of Utah Health (U of U Health), to share the organization's experience on implementing an automated audit process.
Draper says that "quality is always top of mind. Our teams are always looking for better ways to be efficient and bring stronger value to our organization."
Helping to oversee the execution of the new auditing software within the coding department was Nancy Treacy, MPH, RHIA, CDIP, CCS, who works in data integrity at U of U Health.
"Implementing new processes within the revenue cycle takes time and work. But taking the leap from a manual, disparate process to an automated and streamlined one is worth the growing pains," says Treacy.
Since implementation, Draper says that multiple owners in the audit process now utilize a single platform to record, communicate, educate, and manage outcomes with one consistent tool at their organization.
U of U Health has also seen a number of tangible benefits, including a monthly production increase of retrospective audits that went from 5% to 10%.
"The ability to drive postbill and prebill audits heightens our capacity to change," says Draper. "It also improves coding compliance, creates timely feedback through training and education, and enhances reporting to measure against our revenue integrity goals."
U of U Health has a dedicated commitment to quality, which is why it works across its revenue cycle with an integrated auditing and coding team made up of nurses, coders, auditors, educators, and quality liaisons.
The team works closely together, sharing information and communicating openly, says Treacy.
"Like many other health systems, our audit process started in a spreadsheet-based world. Each auditor had their own spreadsheet, their own process, and focused on different audit elements. It was not a unified approach and led to sharing dissimilar feedback in different formats for our coders," says Treacy.
The organization went through several iterations to streamline this process, but from unifying spreadsheets and conventions to trying to automate portions by hand, everything was still too manual.
It was taking too long to find trends and stats within the data available, says Treacy.
This is when revenue cycle leaders stepped in, as they were approached to test out new auditing software.
U of U Health's coding and clinical documentation integrity departments were already using the 3M™ 360 Encompass™ system, so when asked about being a beta site for the 3M 360 Encompass Audit Expert System | Code Audit software, they jumped at the opportunity.
The organization's goal was to ultimately become more efficient. Through its work as a beta site, U of U Health was able to establish a process that would identify potential errors at the point of coding and manage all coding and review activity within a single platform.
Transitioning to the prebill review process was also important to the organization to eliminate rebills, enabling coders and auditors to work together and provide timelier, more complete feedback. This, integrated with their retrospective audit process, helped streamline the prospective and retrospective process.
According to Treacy, the organization is now able to:
Conduct the prebill auditing process in a quicker timeframe, resulting in billing the account just one time
Increase prebill audit numbers from a handful of audits each month to an even split between retrospective audits and prebill audits
Because of the success of having an automated audit process, Treacy outlined three keys to success that she says helped U of U Health, and in turn, can help other organizations hoping to streamline their audit processes.
Key 1: Find a champion
Like any other big change, finding someone who believes in it, can build the business case, and shepherd the change from start to finish is a critical part in finding long-lasting success.
Champions need to be people who see the opportunity and can rally necessary stakeholders around the cause. They can encourage others to get involved and feel invested, and they should be the first ones to bring the team back to the vision when needed.
Key 2: Communicate early and often
Start conversations about changes long before change happens. U of U Health had an ongoing dialogue with team leaders early on, before implementation, to keep them informed, get their feedback, and manage their expectations. The champion should also work to build a strong, open rapport with stakeholders before challenges arise.
Key 3: Build smart, not fast
While time is always of the essence in the revenue cycle, implementing wider-scale change, like new processes and software, is better taken at a methodical pace.
U of U Health was careful not to do too much too soon and wanted to be sure the workflow was right before getting too far into the process, says Treacy. And at least once in the process, it held off on implementing the next stage until issues were resolved and teams were truly ready to move on.
A timeline should be realistic and have a level of flexibility to it.
As revenue cycle leaders toy with the idea of looping in directors and managers on ways to improve their audit processes, it's important to remember that audits have benefits outside of the organization as well.
The ultimate reason for automating and streamlining an audit process goes far beyond making the jobs of those in the middle revenue cycle easier, says Treacy.
"I believe coders and auditors are patient advocates. Patients are tasked with so much responsibility beyond focusing on getting well, and we help make sure they have a quality experience all the way to the end. With the proper tools and processes, we can ensure they get sent only one claim, helping to reduce confusion about what they can expect to pay. That's something we take seriously and are proud of," says Treacy.
The department details the steps it is taking to conform to a recent court order that struck down a piece of the arbitration process in the No Surprises Act.
A federal court in Texas recently ruled in favor of the Texas Medical Association, deciding that HHS was mistaken in its decision to instruct mediators to give past contracted rates between insurers and providers extra weight compared to other factors during the independent dispute resolution (IDR) process within the No Surprises Act.
This ruling sent waves across the U.S., and one of the latest entities to comment is the Department of Labor, which issues the No Surprises Act alongside HHS and the Department of Treasury.
"This court order did not affect any of the departments' other rulemaking under the No Surprises Act. Thus, consumers continue to be protected from surprise bills for out-of-network emergency services, out-of-network air ambulance services, and certain out-of-network services received at in-network facilities," the Department of Labor's memorandum said.
The three departments are collectively reviewing the court's decision and considering next steps, but according to the memorandum the departments will immediately:
Withdraw guidance documents that are based on, or that refer to, the portions of the rule that the court invalidated
Provide training on the revised guidance for certified IDR entities and disputing parties
Open the IDR process for submissions through the IDR portal
During the IDR process, an arbiter is directed to consider all information submitted by the physician and insurer, including the median in-network rate, complexity of the case, previously contracted rates, and market power of the physician and insurance company, among other items.
The law states that the qualified payment amount (QPA) could be one of many equally weighted factors considered in payment disputes.
However, until now, the rule made the QPA the primary factor in the IDR process. Organizations have said that since the QPA is "an unverified rate set by insurers," using it to settle disputes "sets an artificially low benchmark payment, for all care—whether in network or not, which may not support wider access to care—particularly in underserved areas."
This lawsuit does not impact No Surprises Act protections to hold patients harmless during insurer-provider out-of-network payment disputes and will not increase patient out-of-pocket costs.
Although the U.S. timeline for implementing ICD-11 is still up in the air, the new code set is now officially in effect for the reporting of causes of illness, death, and more.
The World Health Organization (WHO) officially released ICD-11, the newest code set that WHO member countries will be implementing worldwide. According to the WHO press release, 35 countries have already started reporting with ICD-11.
According to the WHO, compared with previous versions, ICD-11 is entirely digital with a new user-friendly format and multilingual capabilities that reduce the chance of error.
"A key principle in this revision was to simplify the coding and provide users with all necessary electronic tooling—this will allow healthcare professionals to more easily and completely record conditions," Robert Jakob, team lead of classifications terminologies and standards at the WHO, said in a press release.
Since ICD-11's release for testing in 2016, the WHO says it has considered 900 proposals for input from early adopter countries and scientific groups. According to the WHO, key updates for ICD-11 include:
Clinical descriptions and diagnostic requirements for mental health
Grade and stage coding for cancers
Rare disease coding
Support for perinatal and maternal coding
Among other updates, ICD-11 improves the clarity of terms for the general public and facilitates the coding of important details such as the spread of a cancer or the exact site and type of a fracture, the WHO said.
ICD-11 also includes updated diagnostic recommendations for mental health conditions and digital documentation of COVID-19 certificates.
While it may seem like revenue cycle leaders just recovered from the transition from ICD-9 to ICD-10, the implementation of ICD-11 in the U.S. is likely to be far in the future.
Last year, the National Committee on Vital and Health Statistics made recommendations regarding the transition to ICD-11 and stressed the immediate need for more research and communication.
Due to setbacks in research caused by COVID-19, the National Committee on Vital and Health Statistics says its delayed action has only increased the urgency to commence research, strategic communications, and outreach.
According to the committee, the following two conditions should be met before an ICD-11 implementation in the U.S.:
HHS should conduct research to evaluate the impact of different approaches to the transition and implementation of ICD-11
HHS should conduct outreach and communicate regularly to the U.S. healthcare industry about the ICD transition
"We put these [recommendations] forward now to avert significant avoidable transition cost and burden to the US health care system, including public health, like those experienced in the recent transition from ICD-9 to ICD-10," the committee said.
According to an ICD-11 fact sheet from the WHO, countries who have not used a previous version of ICD and have a simple information system may need one to two years to completely transition to ICD-11 reporting.
Conversely, systems where versions of ICD are already in use, such as in the U.S. with ICD-10, four to five years may be required to fully transition to ICD-11.
In new guidance, CMS outlines how good faith estimates must be provided by the front-end revenue cycle.
CMS has recently published information concerning the good faith estimate provision of the No Surprises Act, which took effect January 1.
Healthcare organizations are now required to issue an estimate of the expected charges of a scheduled item or service to uninsured or self-pay individuals. This estimate prevents the patient from receiving surprise medical bills after the item or service is complete.
Looping in revenue cycle staff is essential since CMS further explains these requirements and how they can be implemented effectively in its latest guidance.
Some of the topics discussed include:
Definitions of the healthcare providers and facilities that must comply with the good faith estimate requirements, as well as the patients who must receive good faith estimates
How and in what forms good faith estimates must be provided and the administrative burden of doing so
Hospital leaders should review the good faith estimate requirements and CMS guidance to ensure they are acting in compliance with the No Surprises Act.
This is the latest guidance provided for organizations regarding good faith estimates and the No Surprises Act.
Previously, the American Hospital Association (AHA) published a No Surprises Act legislative advisory report that includes key takeaways about the law along with a 15-page detailed summary of the rule.
In addition, the legislative advisory webpage links to additional resources, including an FAQ for members about the uninsured/self-pay good faith estimate; details about the AHA/American Medical Association (AMA) lawsuit challenging how federal regulators proposed resolving billing disputes; and information about CMS guidance.
