Therapy is a relationship that works in part because of clearly defined rights and responsibilities held by each person. This frame helps to create the safety to take risks and the support to become empowered to change. As a client in psychotherapy, you have certain rights that are important for you to know about because this is either you or your child’s therapy, whose goal is your well-being. There are also certain limitations to those rights that you should be aware of. Small Steps reserves the right to update, and amend all policies and protocols as needed with or without notice to achieve best practices.

OUR RESPONSIBILITIES AS YOUR MENTAL HEALTH PROVIDER

I. CONFIDENTIALITY

With the exception of certain specific exceptions described below, you have the absolute right to the confidentiality of your therapy. Small Steps cannot and will not tell anyone else what you have told your Small Steps therapist, or even that you are in therapy with Small Steps without your prior written permission. Small Steps will always act so as to protect your privacy even if you do release Small Steps in writing to share information about you. You may direct Small Steps to share information with whomever you chose, and you can change your mind and revoke that permission at any time.  

In many cases Small Steps therapists see multiple members of the same family. It is pertinent in the treatment process of this family for the therapists to coordinate care and develop treatment plans together with the family members. Interagency treatment coordination between therapists is necessary to provide optimal treatment for the whole family.  

 All Small Steps therapists are engaged in weekly or bi-weekly supervision with a member of the supervisory team. Client information may be discussed with any member of the supervisory team to support ethical and effective treatment of the client.

 You are also protected under the provisions of the Federal Health Insurance Portability and Accountability Act (HIPAA). This law insures the confidentiality of all electronic transmission of information about you. Whenever Small Steps transmits information about you electronically (for example, sending bills or faxing information), it will be done with special safeguards to insure confidentiality. If you elect to communicate with your therapist by email at some point in your work together, please be aware that email is not completely confidential. Any email Small Steps receive from you, and any responses that we will send to you, will be printed out and kept in your treatment record.

The following are legal exceptions to your right to confidentiality.  The therapist will inform you of any time when we think we will have to put these into effect.

1. If the therapist has good reason to believe that you will harm another person, the therapist must attempt to inform that person and warn them of your intentions. The therapist must also contact the police and ask them to protect your intended victim.

2. If the therapist has good reason to believe that you are abusing or neglecting a child or a vulnerable adult, or if you give the therapist information about someone else who is doing this, the therapist must inform Child Protective Services or Adult Protective Services immediately.

3. If the therapist believes that you are in imminent danger of harming yourself, the therapist may legally break confidentiality and call the police. The therapist is not obligated to do this, and would explore all other options with you before they took this step. If at that point you were unwilling to take steps to guarantee your safety, the therapist would call the police.

II. RECORD KEEPING

Small Steps keeps very brief records, noting only that you have been here, what interventions happened in session, and the topics discussed. You have the right to request that we make a copy of your file available to any other health care provider at your written request. Your records remain in a secure location that cannot be accessed by anyone else.

Does a parent have a right to receive a copy of psychotherapy notes about a child’s mental health treatment?

No.  HIPAA defers to State Law in protection of Child Mental Health Records:  NMSA § 32A-6A-24(A) (2008) states that a treating entity requires a Release of Information for children 14 and over to release treatment information to caregivers.  For children under the age of 14, the treatment provider, defined as  “mental health or developmental disabilities professional” means a person who by training or experience is qualified to work with persons with mental disorders or developmental disabilities” can release a “summary of the child’s assessment, treatment plan, progress, discharge plan and other information essential to the child’s treatment” to the child’s personal representative unless the treating entity believes it would cause the child harm.  Nothing in State Law shall prohibit the denial of access to the records when a physician or other mental health or developmental disabilities professional believes and notes in the child's medical records that the disclosure would not be in the best interests of the child. § 32A-6A-24(G).

However, parents generally are the personal representatives of their minor child and, as such, are able to receive a copy of their child’s mental health information contained in the medical record, including information about diagnosis, symptoms, treatment plans, etc.    Further, although the HIPAA Privacy Rule does not provide a right for a patient or personal representative to access psychotherapy notes regarding the patient, HIPAA generally gives providers discretion to disclose the individual’s own protected health information (including psychotherapy notes) directly to the individual or the individual’s personal representative.  As any such disclosure is purely permissive under the HIPAA Privacy Rule, mental health providers should consult applicable State law for any prohibitions or conditions before making such disclosures.

Small Steps policy is to not disclose any psychotherapy notes without the express written consent of the client and/or client representative and to that end will only disclose records to other providers for continuity of care. All requests for records must be submitted in writing and will be processed within 30 days of the request. Small Steps does charge a fee for all records requested.

III. DIAGNOSIS

 If a third party such as an insurance company is paying for part of your bill, the therapist is normally required to give a diagnosis to that third party in order to be paid. Diagnoses are technical terms that describe the nature of your problems and something about whether they are short-term or long-term problems. If we do use a diagnosis, we will discuss it with you. All of the diagnoses come from the DSM-V.

 IV. OTHER RIGHTS

You have the right to ask questions about anything that happens in therapy. Small Steps Therapists are always willing to discuss how and why your therapist has decided to do what they are doing, and to look at alternatives that might work better. You can ask the therapist about their training for working with your concerns, and can request that they refer you to someone else if you decide they are not the right therapist for you. You are free to leave therapy at any time.

 V. MANAGED MENTAL HEALTH CARE

If your therapy is being paid for in full or in part by a managed care firm, there are usually further limitations to your rights as a client imposed by the contract of the managed care firm. These may include their decision to limit the number of sessions available to you, to decide the time period within which you must complete your therapy with your therapist, or to require you to use medication if their reviewing professional deems it appropriate. They may also decide that you must see another therapist in their network rather than your current therapist.  Such firms also usually require some sort of detailed reports of your progress in therapy, and on occasion, copies of your case file, on a regular basis. Small Steps does not have control over any aspect of their rules. However, we will do all that we can to maximize the benefits you receive by filing necessary forms and gaining required authorizations for treatment, and assist you in advocating with the MC company as needed.

VI. YOUR RESPONSIBILITIES AS A THERAPY CLIENT

Our standard fee for an initial intake session is $120.00 and an individual therapy session is $75.00 per 45-minute session, payable at the beginning of each session.  We are a provider for multiple insurances and all insurance billing will go through Therapy Notes. Co-pays can be made by check, credit card or cash (correct change is appreciated). Your checks are to be made payable to Small Steps Child Counseling. There will be a $35.00 service charge on all returned checks.

Please inform us if any problem arises during the course of therapy affecting your ability to make timely payments. Any services provided such as report writing, phone-consultations, or phone sessions that last longer than fifteen minutes will be billed on a prorated basis.

 Sessions last for 45- 50 minutes. If you are late, we will end on time and not run over into the next person's session. If your therapist is running behind you will receive the entire time of your scheduled session. If you cancel without 24 hours notice, you may lose your weekly time slot.

 If you have insurance, you are responsible for providing Small Steps with the information we need to send in your bill. You must pay Small Steps your deductible at the beginning of each calendar year if it applies and any co-payment at each session. Our insurance billing is completed in-house using Therapy Notes. Billing questions may be directed to our Business Operations Manager Kim Stout at (505) 349-5470.   

Should your patient balance exceed $200 we may suspend services until the account is brought current. If the insurance balance exceeds $500 we may suspend services to allow time for the outstanding claims to process. Should the account remain outstanding without payment arrangements for 60 days it will be sent to collections and a 20% fee added to the balance.

VII. COMPLAINTS

If you're unhappy with what's happening in therapy, we hope you'll talk about it with your therapist so that we can respond to your concerns. We will take such criticism seriously, and with care and respect. If you believe that we have been unwilling to listen and respond, or that we have behaved unethically, you can complain about our behavior to the New Mexico Counseling and Social Work Licensing Board. You may also contact our Business Operations Manager Kim Stout (505) 349-5470.

VIII. TELEPHONE & EMERGENCY PROCEDURES:

 Please feel free to leave a message for us at (505) 933-4639. Your call will be returned as soon as possible during regular business hours (9 a.m. - 6 p.m.). Messages are checked frequently during the day. Your call will be received within 24 hours even on weekends. Special arrangements can be made as needed for contact during periods of crisis. Your therapist will arrange for telephone coverage by a qualified therapist if they are out of town. In the event of a sudden emergency, please leave a message on our service clearly indicating that it is an emergency and also call 9·11 (Police/Ambulance) or proceed to your nearest emergency room for immediate assistance. 

IX. TERMINATION:

In initial meetings, we will assess whether our services can be of benefit to your child. We do not accept clients we do not believe we can help. In such a situation, we will provide you referrals to other therapists you can contact. If at any point during psychotherapy your therapist assess that the treatment is not effective in helping your child reach their therapeutic goals, the therapist is obligated to discuss it with you and, if appropriate, terminate treatment.

 The Health Insurance Portability and Accountability Act (HIPAA) provide safeguards to protect your privacy. Implementation of HIPAA requirements officially began on April 14, 2003. Many of the policies have been our practice for years. What this is all about specifically, there are rules and restrictions on who may see or be notified of your Protected Health Information (PHI). These restrictions do not include the normal interchange of information necessary to provide you with office services. HIPAA provides certain rights and protections to you as the patient. We balance these needs with our goal of providing you with quality professional service and care.

Additional information is available from the US Department of Health and Human Services, www.hhs.gov.

We have adopted the following policies:

1. Patient information will be kept confidential except as is necessary to provide services or to ensure that all administrative matters related to your care are handled appropriately. This specifically includes the sharing of information with other healthcare providers, laboratories, health insurance payers as is necessary and appropriate for your care. Patient files may be stored in open file racks and will not contain any coding which identifies a patient's condition or information which is not already a matter of public record. The normal course of providing care means that such records may be left, at least temporarily, in administrative areas such as the front office, examination room, etc. Those records will not be available to persons other than office staff. You agree to the normal procedures utilized within the office for the handling of charts, patient records, PHI and other documents or information.

2. It is the policy of this office to remind patients of their appointments. We may do this by telephone, text, e-mail, U.S mail, or by any means convenient for the practice and/or as requested by you. We may send you other communications informing you of changes to office policy and new technology that you might find valuable or informative.

3. The practice utilizes a number of vendors in the conduct of business. These vendors may have access to PHI but must agree to abide by the confidentiality rules of HIPAA.

4. You understand and agree to inspections of the office and review of documents which may include PHI by government agencies or insurance payers in normal performance of their duties.

5. You agree to bring any concerns or complaints regarding privacy to the attention of the office manager or the clinical director.

6. Your confidential information will not be used for the purposes of marketing or advertising of products, goods or services.

7. We agree to provide patients with access to their records in accordance with HIPAA and state and federal laws.

8. We may change, add, delete or modify any of these provisions to better serve the needs of the both the practice and the patient.

9. You have the right to request restrictions in the use of your protected health information and to request change in certain policies used within the office concerning your PHI. However, we are not obligated to alter internal policies to conform to your request.

We, the parents of the enrolled child(ren) are authorizing our child(ren) to participate in therapy through Small Steps Child Counseling. We understand that the purpose of this therapy is to provide our child(ren) with a neutral professional with whom they may talk openly about personal difficulties. We understand that in order for a child to benefit from these sessions, they must be private and confidential in order to protect confidentiality we agree to the following rules and expectations:

A)     The sessions between our child (ren)/family and the therapist of Small Steps will be confidential under the same rules that apply in adult psychotherapy as described in the *Ethical Standards for Professional Counselors.

B)     Neither of us will ask the therapist to participate in any court proceedings regarding custody, time-sharing, or other Family Court matters regarding our child (ren)/family in therapy.

C)     We will not submit the therapist’s name as a witness in any legal proceeding, nor ask that they be subpoenaed. We understand that the therapist will move to quash any subpoena and request legal fees for any costs involved in the attempt made to involve them in court matters. Minimum fees to quash a subpoena is $200.00.

D)     A release of information to provide treatment by another professional must be signed by both of us, and will be honored by the therapist only if the child (ren)'s/family’s confidentiality will be maintained.

E)     We understand that the therapist will inform us only of the following in regards to statements made by the child (ren)/family in times of therapy:

1.      Information leading to a suspicion that a child is being abused or neglected, that is resulting from unfit care by a parent or other adult. Such information will be referred to the New Mexico Human Services Department for investigation, as required by law.

2.      Information that the child (ren) or family is/are in danger to themselves or to others.

3.      Information revealing when the child (ren) or family is brought to sessions, and by whom.

4.      Information that the child agrees that the therapist should reveal to one or both parents and that the therapist believes is in the child (ren)'s or family’s best interest to reveal.

I/We further agree to support the confidentiality of the sessions by not asking the child(ren) or family about the content of the sessions, and by clarifying to the child(ren)/family that it is not necessary to reveal such information, in the case that the child(ren) or family is/are bringing the information up voluntarily. I/We are the custodial parent(s) or legal guardian(s) of the child(ren) entering treatment. I/We understand and have discussed any questions or concerns with the therapist. I/We consent to have my minor child(ren)/family participate in treatment.

What I Do:

1.   Provide counseling for children, adolescents, couples, and families which supports mental health and family dynamics.

2.   Recommend books, support groups, classes, and information for parents that may help with custody, visitation, and shared parenting circumstances.

3.   For court-ordered clients, record and report the number of sessions attended, session dates, and client's involvement in therapy.

4.   Report harm to self or others according to New Mexico Law.

 What I Do NOT Do:

1.   Mediation

2.   Get involved in the legal aspects of court cases or testify in court, except in special circumstances and with specific arrangements between myself and the judicial system.

3.   Make recommendations for parenting time, custody or visitation for children in divorce and separation situations.

4.    Evaluate a child for possible sexual or physical abuse or neglect.

1.     You are expected to display the same reasonable behavior of any person. In counseling, emotional expressions are appropriate; however, extreme behavior is not. Your behavior may not violate New Mexico State Criminal Statutes, especially as they relate to harm to self or the person or property of others.

 2.     In order to promote the successful resolution of the reasons you came to counseling, you will in general be expected to work toward mutually agreed upon goals.

 3.     You are expected to pay the agreed upon rate for services.

 4.     You are expected to attend your appointments as scheduled, or to give 24-hour notification if an appointment will be missed. Clients who miss appointments or cancel late will be charged for the session and may have their cases closed.

 5.     It is important to come to counseling sessions with a clear mind. If you are under the influence of any mind-altering chemical, you will be asked to reschedule for another time and will be charged for the session.

 6.     Clients are expected to arrange for childcare for sessions in order to participate fully in your therapy. Children are very sensitive to emotions and it is not appropriate that they be present for parents’ sessions. Also, for liability reasons, children under twelve may not wait in the waiting room unaccompanied. Therapists will need to reschedule appointments if children are brought unsupervised. You may be charged for the session.

Therapists with Small Steps Child Counseling pledge to protect the rights of each individual who is provided counseling services.

You, as my client have the right:

1.      To give informed consent.

2.      To refuse Treatment.

3.      To be advised of the potential consequences of refusing treatment or medication.

4.      To actively participate in the development of an individualized treatment plan/goals.

5.      To know the qualifications of staff providing treatment.

6.      To a grievance procedure.

7.      To a humane and safe environment.

8.      To be free from abuse, neglect, and exploitation.

9.      To dignity.

10. To personal privacy and confidentiality.

11. To free communication within the constraints of the individualized treatment plan.

12. To have the justification for any restrictions on communications documented in the client record.

13. To know the cost of treatment.

14. To know about third party coverage of treatment, including full charge and any available sliding scale program assistance.

15. To be informed as to any limitations of treatment or services for the duration of the treatment.

16. To refuse to participate in research.

17. To not be refused access to services without informed communications from counselor and informed as to reason and duration of this decision.

18. To receive a complete explanation of client rights in clear, non technical terms and in a language the client can understand.

19. To receive treatment that is non-discriminatory based on race, gender, religion, age, disability, or sexual orientation.

 I am aware that the practice of psychotherapy is not an exact science and that results cannot be guaranteed.  No promises have been made to me about the results of treatment.

The risks, benefits, side effects, and alternatives of treatment as well as the consequences of non-compliance with treatment have been discussed with me and I have had the opportunity to ask questions.

I understand that I need to provide accurate information about myself/my child to the clinician so that I or my child will receive effective treatment.  I also agree to play an active role in the treatment process. 

I understand that I may terminate treatment for myself or my child at any time.

I understand and agree with all of the above statements.  I have had the opportunity to ask questions about the treatment process.  If the client is a minor or has a legal guardian appointed by the court, the client’s parent or legal guardian must consent.

You have the right to terminate you or your child’s therapy at any time. If you choose to do so, Small Steps will offer to provide you with names of other qualified professionals whose services you might prefer.               

We believe the ending of a relationship is as important as the beginning and the middle. When it is time to terminate, we believe it is important to have a final session to review our work together and provide closure for all of us.

In the event, that your therapist would be unable to continue you or your child's treatment, due to sudden change in life circumstances or death, your child's records will be handled confidentially by a selected mental health colleague and referred to an appropriate provider.

Attendance

1.       Attendance is essential to the clinical effectiveness of working with your family.  Adherence to all appointments is crucial in order to achieve the goals set forth in the treatment plan.

2.       Since the scheduling of an appointment reserves that time specifically for you, a minimum of 24 hours’ notice is required for the rescheduling or cancellation of an appointment. 

3.       After 3 missed appointments without sufficient notice, I may lose my regularly scheduled time slot or may be referred to another agency for services.

Billing and Statements

Small Steps accepts most major insurance and does the billing for you.  We use the following codes to bill for the services provided:               

                                90791 – The initial consultation with parents

                                90832 – A 30 minute therapy session with the patient

                                90834 – A 45 minute therapy session with the patient

                                90837 – A 60 minute therapy session with the patient

                                90846 – A consultation with out the patient present

                                90847 – A family counseling session

                                90853 – A session including 2 or more people

                                90875 – An interactive complexity code

                                90839 – A patient in an emergency crisis, 60 minutes

                                90840 – A patient in an emergency crisis, an additional 30 minutes

 We ask that a credit card be placed on file so that the copay’s and uninsured amounts can be charged to the card in a timely manner.  However, we cannot bill your credit card until after we confirmed your deductible has been met and what the insurance company shows as your copay. Small Steps will make best efforts to charge copays and deductibles for services within 2 weeks of date of service. 

Although Small Steps makes every attempt to confirm insurance coverage, deductible amounts and copay information, it is your responsibility to know and keep track of your deductible and how much of that you have met along with your copay amounts.  You will receive a statement each month with the balance owed on your account and a prompt payment is expected.  If your account accrues a past due balance for more than 30 days, services may be suspended until the account is brought current. Should the account remain outstanding without payment arrangements for 60 days it will be sent to collections and a 20% fee added to the balance. Should the insurance become inactive upon monthly verification, services will cease immediately unless it is deemed therapeutically harmful by the therapist. 

Billing questions and payments should be directed to our Business Operations Manager Kim Stout at 505-349-5470.

Small Steps Child Counseling has instituted an Appointment Cancellation and Missed Appointment Policy. A cancellation made with less than 24 hour notice significantly limits our ability to make the appointment available for another patient in need. Multiple Cancellations in a month significantly limits our ability to provide adequate treatment to your child/family.

 To remain consistent with our mission, we have instituted the following policy:

 Please provide our office a 24 hour notice in the event that you need to reschedule your appointment. This will allow us the opportunity to provide care to another patient. A message can always be left on our voicemail to avoid a “No-Show”.

• After 1 “No-Show” or cancellation within 24 hours, your therapist will be in communication with you that week. After a 2nd no show, or cancellation within 24 hours, you may lose your regularly scheduled appointment time.

• After 2 cancelled appointments within a month you also may lose your regularly scheduled appointment time.

• After 3 “No-show” or cancellations within 24 hours, you will be referred to another mental health provider for services.

 If you have any questions regarding this policy, please let our staff know and we will gladly clarify any questions you have. A copy of this policy will be provided to you if need be. Please sign and date below to show your acknowledgement.  

I have read and understand the Appointment Cancellation Policy and I acknowledge its terms. I also understand and agree that such terms may be amended from time to time by the clinic.

Small Steps keeps very brief records, noting only that you have been here, what interventions happened in session, and the topics discussed. You have the right to request that we make a copy of your file available to any other health care provider at your written request. Your records remain in a secure location that cannot be accessed by anyone else.

Does a parent have a right to receive a copy of psychotherapy notes about a child’s mental health treatment?

No.  The HIPAA Privacy Rule distinguishes between mental health information in a mental health professional’s private notes and that contained in the medical record.  It does not provide a right of access to psychotherapy notes, which the HIPAA Privacy Rule defines as notes recorded by a health care provider who is a mental health professional documenting or analyzing the contents of a conversation during a private counseling session or a group, joint, or family counseling session and that are separate from the rest of the patient’s medical record.  See 45 CFR 164.501.   Psychotherapy notes are primarily for personal use by the treating professional and generally are not disclosed for other purposes.  Thus, the HIPAA Privacy Rule includes an exception to an individual’s (or personal representative’s) right of access for psychotherapy notes. See 45 CFR 164.524(a)(1)(i).

However, parents generally are the personal representatives of their minor child and, as such, are able to receive a copy of their child’s mental health information contained in the medical record, including information about diagnosis, symptoms, treatment plans, etc.    Further, although the HIPAA Privacy Rule does not provide a right for a patient or personal representative to access psychotherapy notes regarding the patient, HIPAA generally gives providers discretion to disclose the individual’s own protected health information (including psychotherapy notes) directly to the individual or the individual’s personal representative.  As any such disclosure is purely permissive under the HIPAA Privacy Rule, mental health providers should consult applicable State law for any prohibitions or conditions before making such disclosures.

Small Steps policy is to not disclose any psychotherapy notes without the express written consent of the client and/or client representative and to that end will only disclose records to other providers for continuity of care. All requests for records must be submitted in writing and will be processed within 30 days of the request. Small Steps does charge a fee for all records requested.

 What is Coordination of Benefits?

Coordination of Benefits (COB) is a process where individuals, couples or families who are covered under more than one health plan combine their coverage to maximize their benefits. One plan becomes the primary plan and pays benefits first while the other plan becomes the secondary plan and pays the remaining balance for eligible expenses. It is crucial that a COB is set up to avoid rejected claims, and ultimately, the patient becoming responsible for any and all charges for services. Ultimately, both insurances need to be aware of each other, and need to know who the primary and secondary provider/payer is. You and your insurance companies are responsible for deciding what provider is primary and what provider is secondary.

Examples of COB include:

Children covered under both parents’ plan (i.e. Medicaid and another commercial company’s health plan)

Children covered under both parents’ plan (i.e. A BCBS commercial plan through Mom, and a Pres commercial plan through Dad)

It is our policy to obtain proof of COB before scheduling a potential client with dual insurance coverage. We must be provided a contact name and a reference/ticket # regarding the conversation you’ve had with BOTH of your insurance providers around setting up a COB, this way we can contact both companies to verify that they know who the primary and secondary payers are, so that in turn, we will have the information needed to properly bill both providers without kickbacks.

If a client at Small Steps obtains dual coverage while being seen here, the responsible parties will have 14 days to provide proof of COB between insurances or services may be suspended.

What is a THIRD-PARTY PAYER?

THIRD-PARTY PAYERS are accounts that have been established to pay healthcare costs that are separate than your health insurance provider. Examples of these types of accounts include but are not limited to Flexible Spending Account (FSA), Health Savings Account (HSA), and Health Reimbursement Arrangement (HRA).

Some of the THIRD-PARTY PAYERS are established with an insurance plan like Blue Cross Blue Shield (BCBS) and Connect Your Care (CYC). Small Steps submits the claims for services rendered to BCBS and then the copay or deductible is issued from CYC. This is just one example of this to refer to.

If you have a THIRD-PARTY PAYER account Small Steps will make best efforts to accept and process these claims and payments. As with any insurance provider or THIRD-PARTY PAYER in the event there is underpayment it is the responsibility of the Patient and/or Patient Guardian to remit any outstanding balance owed for services rendered. In the event there is an overpayment from the THIRD-PARTY PAYER refunds will not be processed until all pending claims have processed and been paid.

Small Steps reserves the right to make updates and changes to this policy as needed to reflect best practices.

Email and text messaging allows Small Steps Child Counseling health care providers to exchange information efficiently for the benefit of our patients. At the same time, we recognize that email and text messaging are not a completely secure means of communication because these messages can be addressed to the wrong person or accessed improperly while in storage or during transmission.

You are not required to authorize the use of email and/or text messaging and a refusal will not affect your health care in any way.

If you prefer not to authorize the use of email and/or text messaging we will continue to use U.S. Mail or telephone to communicate with you. Please send an email to us indicating you do not want to receive email or text communications.

This policy ensures that clients receive a transparent and accurate estimate of the costs associated with services before they commit to receiving them. It aims to enhance trust, facilitate informed decision-making, and comply with applicable regulations.

 This policy applies to all services provided by Small Steps Child Counseling and all personnel involved in the provision, billing, and communication of service costs.

Policy Statement:

1. Provision of Good Faith Estimates (GFE):

   • Clients requesting services shall receive a written Good Faith Estimate outlining anticipated costs before services are rendered.

   • The estimate shall include a breakdown of services, applicable fees, and any potential additional costs.

   • If exact pricing is unavailable, the estimate shall include a reasonable range of potential costs.

2. Timeliness of Estimate:

   • The GFE shall be provided in a timely manner, typically within (5) business days of the request or before the scheduled service date, as applicable.

3. Accuracy and Updates:

   • Estimates should be as accurate as possible based on available information at the time.

   • If service needs change, an updated estimate shall be provided as soon as reasonably possible.

4. Client Acknowledgment:

   • Clients shall have an opportunity to review and acknowledge the GFE before services commence.

   • Clients are encouraged to ask questions about the estimate and discuss financial concerns before proceeding.

5. No Obligation:

   • Receiving a GFE does not oblige the client to proceed with services.

   • Clients retain the right to seek services elsewhere if they choose.

6. Regulatory Compliance:

   • The GFE process shall comply with all applicable laws and regulations, including but not limited to the No Surprises Act and state-specific consumer protection laws.

7. Dispute Resolution:

   • Clients who believe they have been billed significantly more than the estimated cost may raise a dispute.

   • The company shall provide a process for reviewing and resolving such concerns in a fair and timely manner.