CMS Delays Enforcement on Phase II of Good Faith Estimate Policy

Sarah Hohman, NARHC Director of Government Affairs


On December 2, CMS issued additional guidance stating that the Good Faith Estimate (GFE) requirement to include cost estimates for co-providers/co-facilities set to go into effect January 1, 2023 has been delayed.

While we acknowledge that the GFE requirements in place since January 1, 2022 continue to present an administrative burden to many RHCs, we are pleased that CMS has not added further complexity to the process at this point.

NARHC thanks all RHCs that submitted feedback on the impacts of GFE policy this fall, assisting us in explaining both the provider and patient viewpoints in our response to the multi-agency Request for Information.

As a reminder, we’ll be covering RHC regulatory updates, including where GFE requirements currently stand, in our free, upcoming webinar this Wednesday, December 7 at 3 pm ET. RHCs can register here. Resources on GFE policy will continue to be updated here.

To view all submitted NARHC Advocacy Letters and Comments, please visit Please contact Sarah Hohman, NARHC Director of Government Affairs,, with any questions or concerns.