Implement patient cost estimation using the AEOB (Advanced Explanation of Benefits) data exchange standard when it becomes effective under the No Surprises Act

Verified steps

1. Monitor the CMS rulemaking timeline for the AEOB final rule, which as of mid-2026 remains in proposed rule stage; track the Federal Register for the final rule and effective date before implementing.
2. When finalized, implement the GFE-to-payer data exchange workflow: the convening provider sends the Good Faith Estimate to the patient's health plan using the FHIR-based GFE coordination workflow.
3. The payer adjudicates the GFE against the patient's benefits and generates an AEOB that includes the plan's estimated responsibility, the patient's estimated cost-sharing, and the provider network status.
4. Ensure the AEOB contains the required statutory elements: network status of the provider, the contracted rate or a description of how to find in-network alternatives, a good faith estimate of the plan's payment, the patient's estimated cost-sharing, and medical management disclaimers.
5. Deliver the AEOB to the patient prior to the scheduled service in the timeframe the final rule specifies; retain a copy for compliance documentation.
6. Test the end-to-end GFE-to-AEOB workflow in a sandbox environment, validating both the GFE FHIR resources and the AEOB FHIR resources against their respective published profiles.