Other Federal Requirements

Federal

Not compliant

Overall Federal Compliance

Federal

No Surprises and Good Faith Estimates

A written office policy is established that outlines all Good Faith Estimate (GFE) procedures, including patient intake screening, notice posting, estimate preparation and delivery, recordkeeping, dispute handling, and staff training.

Read more: Good Faith Estimates No Surprises Act, No Surprises Act applies?, Ask Paxson?

When patients call to schedule an appointment, a written script is available that ensures that staff asks every patient scheduling new services if they are uninsured or choosing to self-pay.

Read more: Good Faith Estimates No Surprises Act, No Surprises Act Applicability, Ask Paxson?

The GFE Patient Rights Notice is posted in a visible location in your office.

Read more: Good Faith Estimates., No Surprises Act Applies?, GFE Poster, Ask Paxson?

The GFE Patient Rights Notice is prominently displayed (and easily searchable from a public search engine) on your website.

Read more: Good Faith Estimates., No Surprises Act, Website language document, Ask Paxson?

A Good Faith Estimate written form is in place for your practice and includes all required elements.

Read more: Good Faith Estimates., No Surprises Act application, GFE Form Template, Ask Paxson?

A staff reminder poster is displayed [1] near the phones, indicating for appointments scheduled 10 or more business days in the future, GFE must be provided within 3 business days after scheduling; for appointments scheduled 3-9 days in the future, GFE must be provided within 1 business day of scheduling; and appointments less than 3 days in the fu have no GFE requirement.

Read more: Good Faith Estimates No Surprises Act, No Surprises Act., Ask Paxson?

A written policy exists [1] that requires that a copy of every GFE provided is kept in the patient’s medical record (paper or electronic) and the date and method of delivery (print, email, etc.) is documented.

Read more: Good Faith Estimates, No Surprises Act and Offices, Ask Paxson?

All staff are trained regarding your specific GFE procedures and requirements.

Read more: Good Faith Estimates, No Surprises Act, No Surprises Act Office Application, Ask Paxson?

Cures Act and Information Blocking

A written policy is in place that outlines practice compliance with the Cures Act, including patient access rights, information blocking prohibitions, and procedures.

Read more: Information Blocking and Records, Information Blocking: How To Guide, Ask Paxson?

Staff training has been completed and repeated annually to ensure all team members understand patient rights under the Cures Act, how to handle record requests, and how to apply exceptions appropriately.

Read more: Information Blocking and Patient Records, Avoiding Information Blocking Guide, Ask Paxson?

If you will use the Infeasibility Under the Circumstances Exception to deny patient access to electronic health information, a clearly written policy is in place that considers all six required factors.

Read more: Information Blocking and Records., Sharing Health Information Properly, Ask Paxson?

If you will use the Preventing Harm Exception to deny patient access to electronic health information, a clearly written policy is in place that requires case-by-case consideration on all required factors.

Read more: Information Blocking and Records., Information Blocking: A How-To, Federal healthcare appeals process., Ask Paxson?

A written policy is in place that establishes when and how the Security Exception may be used to deny patient access to EHI, requiring a documented specific security risk, an updated HIPAA Security Risk Assessment, consistent and non-discriminatory application, and confirmation that patients cannot be denied access to their EHI based solely on concerns about the security of the app or technology they choose to use.

Read more: Information Blocking and Records, Information Blocking How-To Guide, Information Blocking Exceptions., Ask Paxson?

Written procedures are in place to ensure that patient records are provided timely and in the format requested, when feasible, including paper, electronic, or patient app access.

Read more: Information Blocking and Patient Records, Sharing Health Information Properly., Ask Paxson?

A written policy [1] is in place that prohibits charging patients any fees for accessing, downloading, exporting, or sending their electronic health information (EHI), regardless of format.

Read more: Information Blocking and Records, Information Blocking: How to Guide, Ask Paxson?

Antitrust

Written policy established [1] that strictly prohibits discussions or agreements regarding prices with any outside providers.

Read more: Anti-trust Policy, Ask Paxson?

Written policy [1] established that strictly prohibits discussions or agreements regarding network participation with any outside providers (i.e., contracts with insurers).

Read more: Antitrust: A Word of Caution, Ask Paxson?

Written policy established [1] that strictly prohibits discussions or agreements regarding boycotting specific equipment and or service providers with any outside providers.

Read more: Antitrust: A Word of Caution, Ask Paxson?

Written policy established [1] that strictly prohibits discussions or agreements regarding wages to be paid to health care employees with any outside providers.

Read more: Antitrust: A Word of Caution, Ask Paxson?

FinCen Beneficial Ownership Interest (BOI) Filing

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Medicare Revalidation

Check for Medicare Revalidation requirement (and complete if due).

Read more: How To Check Medicare Revalidation Status, Ask Paxson?

Important Note

[1] These written policies are strongly suggested by the Illinois Chiropractic Society but are not requirements of law. The policy will assist your practice in ensuring correct practices and keeping these issues front of mind in the future. The policies will also assist with ongoing compliance and employee training. Remember, they do not have to be long or complicated, and in fact, some may be as short as one sentence.