Why callers do not book a therapy evaluation

For OT, PT and SLP practices serving children, adults or both: a caller who does not book stopped at a point such as service fit, a usable time, cost, a referral or authorization, a phone route they could not use, a lost callback or their choice. Record that point for each unbooked inquiry and fix what the practice controls.

The first call has its own guide: the intake call script gives the words for each step, and the email templates cover written replies. This guide starts where those end, with the call that finished without a booking.

Why do callers not book after contacting a therapy practice?

Because the call ended with something unresolved, or with an accurate answer that the practice cannot help. Seven stall points are worth naming separately, because each has a different owner and a different fix:

Only the last row sits outside the practice’s reach, and the first is a success when the answer was accurate. The work is telling the rows apart. A booking rate that mixes “we do not treat adults with aphasia” with “nobody called back” hides both problems.

How do pediatric and adult callers stall in different places?

They meet the same stall points from different directions. For a child, the caller is a parent or caregiver fitting therapy around school, perhaps asking how outpatient care relates to school services, perhaps waiting on a pediatrician’s prescription or a Medicaid step. For an adult, the caller may be the patient or a spouse or adult child helping, with work hours, transport or a Medicare Advantage plan in the way. An adult with a speech disability after a stroke may call through Speech-to-Speech relay, which the FCC describes as a service used by a person with a speech disability.⁠⁹ The ADA’s effective communication rules cover the person receiving services and, in appropriate circumstances, their parent, spouse or companion.⁠¹⁰

A practice serving both ages should code the two tracks separately, so an after-school capacity problem for children does not hide a callback problem for adults. The children-and-adults launch guide covers running both.

Which decisions does a practice make about unbooked callers?

Seven, and the first is the definition of each stage, because nothing can be counted until everyone logs calls the same way:

Ask for the reason plainly and accept the answer: “Is there anything we could clarify that would help you decide?” A caller who says no has answered. One call is an anecdote; the same code across many calls is a pattern.

What does a caller need to hear before booking an evaluation?

Five answers: who you see, when, where, what it costs and what happens first. A call that leaves one open gives the caller a reason to wait.

The intake call script has the wording for fit, payment, the evaluation and scheduling, and the payment guide has the wording for participation, benefits and self-pay fees. Use them for the words, and this table afterward to find which answer was missing.

What should staff do when they cannot answer a question on the call?

Say who answers it and by when, then make sure it happens: “I don’t have that answer. Our billing coordinator answers fee questions and can call you by Thursday at the number you choose.” Log the question in the caller’s words, with its owner and date, so the follow-up answers what was asked. If the caller is uninsured or self-pay and the question is about cost, the estimate rule below already applies.

What is an uninsured or self-pay caller owed when they ask about cost?

A good faith estimate. Under the No Surprises Act rule, any discussion or inquiry about the potential cost of a service counts as a request for one, and the written estimate is due no later than 3 business days after the request.⁠¹

The rule covers two kinds of caller: a person with no benefits for the service under a health plan, insurance or a federal health care program, and a person with private or federal employee plan coverage who does not want a claim submitted.⁠¹ So the practice asks whether the caller is enrolled in a plan or program and whether they want a claim submitted. It tells uninsured and self-pay callers that an estimate is available, orally when scheduling or when cost questions come up, and in writing on its website, in the office and where scheduling happens, in accessible formats and the languages its callers speak.⁠¹

The estimate has set contents: the patient’s name and date of birth, a plain-language description of the service, an itemized list, diagnosis codes, service codes and expected charges, the provider’s name, National Provider Identifier and Tax Identification Number, services expected to need separate scheduling, and disclaimers, including that it is not a contract.⁠¹ It goes on paper or electronically, as the caller asks; staff may go through it by phone, but the written estimate still has to be issued.⁠¹ If the bill is at least $400 more than the estimate, the patient can start the federal patient-provider dispute process within 120 calendar days of the bill, and CMS tells patients they cannot dispute a bill without an estimate.⁠^2,11

Does a cost question on the phone count as an estimate request?

Yes. The rule tells providers to treat any discussion or inquiry about potential costs as a request for a good faith estimate, so the caller never has to say “estimate.”⁠¹ Log the date of the question as the request date, pass it to whoever issues estimates, and send the estimate even when the caller ends the call to think it over. A posted evaluation fee helps the caller decide, but a fee list is not the estimate.

Can one estimate cover the evaluation and later therapy visits?

It can cover recurring visits once a plan sets them; before the evaluation, estimate the evaluation. At the inquiry stage the estimate lists the services expected to need separate scheduling, such as treatment visits if they are recommended.⁠¹ Once the plan of care sets recurring visits, a single estimate may cover them if it states their expected scope, such as timeframes, frequency and total number, for no more than 12 months.⁠¹

Insured callers who plan to use their coverage need the payment steps instead: participation, benefits, any authorization and their share, each with an owner, worded as the payment guide sets out.

Which referral and payer steps stall a therapy evaluation?

The ones nobody named on the first call: a prescription or referral the payer needs, a prior authorization, a network rule or a state rule on care without a referral. Each depends on the caller’s coverage, and the rules differ for PT, OT and SLP.

Can a PT practice book a caller who has no referral?

Usually, but check the state and the payer first. APTA reports that all 50 states, DC and the U.S. Virgin Islands allow provisional or unrestricted direct access to physical therapists for evaluation and treatment, while some states keep provisions tied to treatment without a referral.⁠⁶ A payer can still require a referral the state does not: HealthCare.gov warns that in many HMOs the plan may not pay without one.⁠⁵ Keep a one-page summary of your state’s rule and each plan’s, so staff answer each combination the same way.

Do OT and SLP callers need a referral before an evaluation?

It depends on the state and the payer, so the answer belongs in the service reference, not in someone’s memory. AOTA notes that occupational therapy practice is regulated by state licensure agencies, and referral requirements are among the state rules it tracks.⁠¹⁶ Medicaid treats OT as prescribed and speech-language services as referred, and Medicare’s plan-of-care rules apply to outpatient PT, OT and SLP alike.⁠^3,4 An SLP practice checks its state licensure law and each payer’s policy, and writes the answer down with the date it was checked.

What should staff tell a caller who is waiting on a referral?

Name the document, who asks for it, and what happens when it arrives: “Your plan asks for a prescription before the evaluation. We can request it from your pediatrician’s office today. When it arrives, our intake coordinator calls you to book; if it has not come by Friday, they call the office again.” HHS states that a provider a patient is referred to for the first time does not need the patient’s written consent to use their information to set up appointments.⁠¹⁷ The pediatrician referral guide and adult referral guide cover the offices that send the paperwork.

How do phone-only intake and access barriers stop bookings?

They stop the caller before fit or cost comes up: a voice line answered only in office hours, a menu with no way to a person, a relay call mistaken for a sales call, no interpreter. The ADA treats the professional office of a health care provider as a public accommodation, which must furnish the auxiliary aids and services needed for effective communication, in a timely way that protects the person’s privacy and independence.⁠^7,18

The telephone rules are specific. A practice must respond to relay calls in the same manner as other calls; any voicemail, messaging or automated menu must give relay users effective real-time communication; and the practice may use relay to return calls.⁠⁷ It may not require a person with a disability to bring someone to interpret, may rely on an accompanying adult only in an emergency, or when the person asks, the adult agrees and it is appropriate, and may not charge a surcharge for the aid.⁠^7,19 The FCC describes relay as letting people with hearing or speech disabilities place and receive calls, with several forms reached by dialing 711, and notes that some people hang up on relay calls thinking the operator is a telemarketer.⁠⁹ ADA.gov’s training point: staff who answer the phone must treat relay calls just like other calls.⁠¹⁰

For an adult with aphasia or dysarthria calling for themselves, that means staying on a slow call or offering a written route, not moving the conversation to a spouse. For a deaf parent calling about a hearing child, the rules apply to the parent.⁠¹⁰ Put a second route, a form or email, on the website and in the voicemail greeting, built as the accessible inquiry forms guide describes.

Which language access steps keep a caller in the intake process?

An interpreter on the first call at no charge, and follow-up the caller can read. A covered entity under the Section 1557 rule, which includes a recipient of federal financial assistance, must take reasonable steps to give people with limited English proficiency meaningful access, free of charge, accurate and timely, with a qualified interpreter when interpretation is needed.⁠^20,21 It must not require a caller to bring or pay for their own interpreter, or rely on a minor child to interpret outside an emergency.⁠²¹ Ask your compliance adviser whether the rule covers your practice. The good faith estimate notice also has to be available in the languages spoken by people considering care.⁠¹ The bilingual and Spanish-language services guide covers building a service in a second language.

How can a practice test its own phone and inquiry routes?

Call them the way a caller does. AHRQ’s health literacy toolkit suggests a “mystery shopper” who acts as a patient during and after business hours, an option to reach a person in any automated system, a menu of no more than five choices and a telephone interpreter when staff do not speak the caller’s language; it notes that some patients hang up when a system is confusing or slow to reach a person.⁠²² Add three checks: the voicemail box has room and its greeting names the hours and the written route; a form submission reaches a monitored inbox; and the after-hours message says when calls are returned.

How do lost callbacks and voicemails end an inquiry?

Quietly: the caller waits, hears nothing usable, and books elsewhere, and the record shows only “left message.” The fix is a contact rule set on the first call and an owner for every callback. HIPAA does not stand in the way: HHS states that the Privacy Rule does not prohibit leaving messages on answering machines, advises limiting what they disclose, such as leaving only the practice’s name and number or asking the person to call back, and allows a limited message with a family member who answers.⁠²³

The caller can also set the route. A provider must accommodate reasonable requests to be contacted by alternative means or at alternative locations and may not require a reason; HHS gives calls at the office rather than at home as a reasonable request.⁠^23,24 So on the first call, settle the best number, whether a message may be left and what it may say, whether text or email is acceptable, and who else may take the call. For a child, that may mean two parents’ numbers; for an adult, whether a helper may take calls at all. If the caller used relay, return the call through relay.⁠⁷

The reply standards guide sets the return time, the owner and backup, and the voicemail wording. Code a callback that never connects as contact lost, not as the caller’s choice.

How do waitlists and appointment times lose callers?

By offering no time the caller can use, or a first date so far out that the evaluation is missed when it comes. A systematic review of 105 studies of missed appointments across medical specialties found high lead time and a prior no-show history to be the most commonly reported significant determinants of no-shows.⁠⁸ Those were not studies of therapy evaluations, so measure your own: the days from booking to the evaluation, and whether long waits are kept less often.

On every unbooked call, record the window asked for beside the times offered. A quarter of those records shows where demand and capacity miss, such as after-school pediatric slots or early-morning adult PT, better than a general sense that people want evenings. In a mixed practice, after-school requests for children and after-work requests for adults can compete for the same block.

When a caller joins the list, the waitlist guide sets out the statuses, the messages and what joining does and does not reserve. A self-pay evaluation booked 10 or more business days ahead still needs its estimate within 3 business days of scheduling.⁠¹

Which public information sends callers the practice cannot book?

Any page or listing that promises an age group, service, hour, setting or payer the practice does not currently offer. Each mismatch produces calls that end in a correct no, and the time spent on them is time not spent calling back callers who fit.

Check every place a caller reads before phoning: the website’s service pages, the Google Business Profile’s hours and services, directory listings and referral handouts. On DrSensory, every clinic has a free basic listing, and a paid listing adds the clinic’s hours, specialties, ages and conditions treated, a description, the website link and family inquiries that come to the clinic; keep those fields matched to what intake can book this month. The profile guide, directory profile guide, Google Business Profile setup guide and website content checklist cover each source. When a fit or time code repeats, find the public sentence that produced those calls and correct it first.

How do you review a call that did not end in a booking?

With a short record made by the person who took the call, while it is fresh: what the caller asked, what was answered, what stalled and what follow-up was promised. Keep it in the practice’s protected system with the rest of the inquiry, and keep clinical detail to what the next step needs.

Use a short, fixed list of reason codes so counts add up across staff:

What should a follow-up message to an unbooked caller say?

The one open item from the call, what the practice has done about it, the caller’s next step, and an easy way to say no. Send it by the route the caller chose, keep clinical detail out of the subject line, and send one follow-up per open item unless the caller asks for more. The email templates include a follow-up for an inquiry that was never answered; this one is for a caller who spoke with you and left with something unresolved.

The estimate itself must be the written document the rule describes, on paper or electronically as the caller asked; a fee sentence in an email does not replace it.⁠¹ Do not treat an inquiry as permission for marketing: a caller who declines leaves the follow-up list and does not join a newsletter.

How do you measure where callers drop out before an evaluation?

Count three stages every month, inquiries, evaluations scheduled and evaluations kept, and divide each by the one before it. Add suitable inquiries as a fourth stage if fit problems are common, so calls the practice could never have booked do not drag down the scheduling rate.

Split every count by discipline, by pediatric and adult, by payer type and by inquiry route, and read each rate beside the reason codes for that stage. With few inquiries a month, one family moves a rate noticeably, so read a quarter together before acting. Compare the practice with its own earlier months, not with a rate from another practice whose services, payers and definitions differ. The listing value guide applies the same counts to a single directory, and the call script explains why booking rate alone is the wrong way to judge intake staff.

Which counts point to a fit problem rather than a process problem?

The stage where inquiries stop, and the codes they carry. Inquiries that never become suitable, coded for fit, point to public information that attracts the wrong calls. Suitable inquiries that stall on cost, payer, access or contact codes point to the intake process, which the practice controls. Time codes point to capacity. A low kept rate beside a long lead time points to scheduling distance, consistent with the review that found lead time among the most common determinants of a no-show.⁠⁸

How might a practice trace a drop in booked evaluations?

By coding every unbooked inquiry for a quarter and acting on the reasons that repeat, as in this hypothetical.

Sources

1. Electronic Code of Federal Regulations. 45 CFR 149.610, Requirements for provision of good faith estimates of expected charges for uninsured (or self-pay) individuals (regulation; eCFR text up to date as of October 22, 2026). Checked October 23, 2026.
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   “An individual who does not have benefits for an item or service under a group health plan”; “Federal health care program (as defined in section 1128B(f) of the Social Security Act), or a health benefits plan under chapter 89 of title 5, United States Code; or”; “but who does not seek to have a claim for such item or service submitted to such plan or coverage”; “Inquiring if an individual is enrolled in a group health plan”; “is seeking to have a claim submitted for the primary item or service with such plan or coverage”; “prominently displayed (and easily searchable from a public search engine) on the convening provider’s or convening facility’s website, in the office, and on-site where scheduling or questions about the cost of items or services occur”; “Orally provided when scheduling an item or service or when questions about the cost of items or services occur”; “Made available in accessible formats, and in the language(s) spoken by individual(s) considering or scheduling items or services with such convening provider or convening facility”; “Convening providers and convening facilities shall consider any discussion or inquiry regarding the potential costs of items or services under consideration as a request for a good faith estimate”; “When a primary item or service is scheduled at least 3 business days before the date the item or service is scheduled to be furnished: Not later than 1 business day after the date of scheduling”; “When a primary item or service is scheduled at least 10 business days before such item or service is scheduled to be furnished: Not later than 3 business days after the date of scheduling”; “When a good faith estimate is requested by an uninsured (or self-pay) individual: Not later than 3 business days after the date of the request”; “A convening provider or convening facility may issue a single good faith estimate for recurring primary items or services”; “the expected scope of the recurring primary items or services (such as timeframes, frequency, and total number of recurring items or services)”; “The scope of a good faith estimate for recurring primary items or services must not exceed 12 months”; “Patient name and date of birth”; “Description of the primary item or service in clear and understandable language”; “Applicable diagnosis codes, expected service codes, and expected charges associated with each listed item or service”; “Name, National Provider Identifier, and Tax Identification Number of each provider or facility represented in the good faith estimate”; “List of items or services that the convening provider or convening facility anticipates will require separate scheduling”; “A disclaimer that the good faith estimate is not a contract”; “A good faith estimate must be provided in written form either on paper or electronically, pursuant to the uninsured (or self-pay) individual’s requested method of delivery”; “the convening provider may orally inform the uninsured (or self-pay) individual of information contained in the good faith estimate using the method requested by the uninsured (or self-pay) individual”; “must issue the good faith estimate to the uninsured (or self-pay) individual in written form”.
2. Centers for Medicare & Medicaid Services. What is a good faith health insurance estimate? (Medical bill rights guide for patients; page last modified October 5, 2026). Checked October 23, 2026.
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   “Usually, if you aren’t using health insurance to pay for your care, your health care provider must give you a good faith estimate of expected charges if you request one or schedule services at least 3 business days in advance.”; “When you schedule care 0-2 business days in advance, you aren’t entitled to get a good faith estimate.”; “When you schedule care 3-9 business days in advance, you’ll get the estimate within 1 business day.”; “When you schedule care 10 or more business days in advance, you’ll get the estimate within 3 business days.”; “You can’t dispute your bill without an estimate.”
3. Centers for Medicare & Medicaid Services. Medicare Benefit Policy Manual, Chapter 15, Covered Medical and Other Health Services (Rev. 13889, issued July 30, 2026; section 220.1.1 and section 220.1.2). Checked October 23, 2026.
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   “Although there is no Medicare requirement for an order, when documented in the medical record, an order provides evidence that the patient both needs therapy services and is under the care of a physician.”; “Payment is dependent on the certification of the plan of care rather than the order”; “Plans of Care for Outpatient Physical Therapy, Occupational Therapy, or Speech-Language Pathology Services”; “The evaluation and treatment may occur and are both billable either on the same day or at subsequent visits.”
4. Electronic Code of Federal Regulations. 42 CFR 440.110, Physical therapy, occupational therapy, and services for individuals with speech, hearing, and language disorders (Medicaid regulation; eCFR text up to date as of October 22, 2026). Checked October 23, 2026.
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   “Physical therapy means services prescribed by a physician or other licensed practitioner of the healing arts within the scope of his or her practice under State law and provided to a beneficiary by or under the direction of a qualified physical therapist.”; “Occupational therapy means services prescribed by a physician or other licensed practitioner of the healing arts within the scope of his or her practice under State law and provided to a beneficiary by or under the direction of a qualified occupational therapist.”; “Services for individuals with speech, hearing, and language disorders means diagnostic, screening, preventive, or corrective services provided by or under the direction of a speech pathologist or audiologist, for which a patient is referred by a physician or other licensed practitioner of the healing arts within the scope of his or her practice under State law.”
5. HealthCare.gov (Centers for Medicare & Medicaid Services). Referral (Glossary). Checked October 23, 2026.
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   “A written order from your primary care doctor for you to see a specialist or get certain medical services. In many Health Maintenance Organizations (HMOs), you need to get a referral before you can get medical care from anyone except your primary care doctor. If you don’t get a referral first, the plan may not pay for the services.”
6. American Physical Therapy Association. Direct Access Advocacy (advocacy issue page). Checked October 23, 2026.
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   “As of July 1, 2025, all 50 states, the District of Columbia, and the U.S. Virgin Islands have either provisional or unrestricted direct access to physical therapist services for evaluation and treatment.”; “Even though patients may go directly to a physical therapist without a referral, some provisions tied to treatment absent a referral still persist in a number of states”.
7. Electronic Code of Federal Regulations. 28 CFR 36.303, Auxiliary aids and services (ADA title III) (regulation; eCFR text up to date as of October 22, 2026). Checked October 23, 2026.
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   “A public accommodation shall furnish appropriate auxiliary aids and services where necessary to ensure effective communication with individuals with disabilities.”; “In order to be effective, auxiliary aids and services must be provided in accessible formats, in a timely manner, and in such a way as to protect the privacy and independence of the individual with a disability.”; “A public accommodation shall not require an individual with a disability to bring another individual to interpret for him or her.”; “A public accommodation shall not rely on an adult accompanying an individual with a disability to interpret or facilitate communication, except”; “In an emergency involving an imminent threat to the safety or welfare of an individual or the public where there is no interpreter available”; “Where the individual with a disability specifically requests that the accompanying adult interpret or facilitate communication, the accompanying adult agrees to provide such assistance, and reliance on that adult for such assistance is appropriate under the circumstances.”; “When a public accommodation uses an automated-attendant system, including, but not limited to, voicemail and messaging, or an interactive voice response system, for receiving and directing incoming telephone calls, that system must provide effective real-time communication with individuals using auxiliary aids and services, including text telephones (TTYs) and all forms of FCC-approved telecommunications relay systems, including Internet-based relay systems.”; “A public accommodation may use relay services in place of direct telephone communication for receiving or making telephone calls incident to its operations.”; “A public accommodation shall respond to telephone calls from a telecommunications relay service established under title IV of the ADA in the same manner that it responds to other telephone calls.”
8. Dantas LF, Fleck JL, Cyrino Oliveira FL, Hamacher S. No-shows in appointment scheduling - a systematic literature review. Health Policy. 2018;122(4):412-421. doi:10.1016/j.healthpol.2018.02.002. PMID 29482948 (abstract, PubMed). Checked October 23, 2026.
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   “A total of 727 articles and review papers were retrieved from the Scopus database (which includes MEDLINE), 105 of which were selected for identification and analysis.”; “the most commonly reported significant determinants of no-show were high lead time and prior no-show history”.
9. Federal Communications Commission. Consumer Guide: Telecommunications Relay Service - TRS (consumer guide; last updated or reviewed August 16, 2022). Checked October 23, 2026.
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   “Telecommunications Relay Service allows persons with hearing or speech disabilities to place and receive telephone calls.”; “Speech-to-Speech Relay Service is used by a person with a speech disability.”; “you can dial 711 to connect to certain forms of TRS anywhere in the United States”; “Some people hang up on TRS calls because they think the CA is a telemarketer.”
10. U.S. Department of Justice, Civil Rights Division. ADA Requirements: Effective Communication (guidance; last updated February 28, 2020). Checked October 23, 2026.
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    “The rules apply to communicating with the person who is receiving the covered entity’s goods or services as well as with that person’s parent, spouse, or companion in appropriate circumstances.”; “The free nationwide telecommunications relay service (TRS), reached by calling 7-1-1”; “Covered entities are also required to accept telephone calls placed through TRS and VRS, and staff who answer the telephone must treat relay calls just like other calls.”; “Covered entities may require reasonable advance notice from people requesting aids or services, based on the length of time needed to acquire the aid or service, but may not impose excessive advance notice requirements.”
11. Electronic Code of Federal Regulations. 45 CFR 149.620, Requirements for the patient-provider dispute resolution process for uninsured (or self-pay) individuals (regulation; eCFR text up to date as of October 22, 2026). Checked October 23, 2026.
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    “Substantially in excess means, with respect to the total billed charges by a provider or facility, an amount that is at least $400 more than the total amount of expected charges listed on the good faith estimate for the provider or facility”; “postmarked within 120 calendar days of receiving the initial bill containing charges for the item or service that is substantially in excess of the expected charges in the good faith estimate”.
12. Centers for Medicare & Medicaid Services, Medicare Learning Network. Complying with Outpatient Rehabilitation Therapy Documentation Requirements (MLN Fact Sheet MLN905365, September 2025). “The physician or NPP certifies the initial POC with a dated signature or verbal order within 30 calendar days from the first day of treatment, including evaluation.” Checked October 23, 2026.
13. Medicare.gov (Centers for Medicare & Medicaid Services). Health Maintenance Organizations (HMOs) (coverage options). Checked October 23, 2026.
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    “An HMO is a type of Medicare Advantage Plan (Part C) offered by a private insurance company.”; “It’s important that you follow the plan’s rules, like getting prior approval for a certain service when the plan requires it.”; “Yes. In most cases, you have to get a referral to use a specialist in HMO Plans.”; “If you get health care outside the plan’s network, you may have to pay the full cost.”
14. Medicaid.gov (Centers for Medicare & Medicaid Services). Early and Periodic Screening, Diagnostic, and Treatment (benefits page). Checked October 23, 2026.
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    “The Early and Periodic Screening, Diagnostic and Treatment (EPSDT) benefit provides comprehensive and preventive health care services for children under age 21 who are enrolled in Medicaid.”; “States are required to provide any additional 1905(a) services that are coverable under the Federal Medicaid program and found to be medically necessary to treat, correct, or reduce illnesses and conditions discovered regardless of whether the service is covered in a state’s Medicaid plan. It is the responsibility of states to determine medical necessity on a case-by-case basis.”
15. HealthCare.gov (Centers for Medicare & Medicaid Services). Preauthorization (Glossary). “Your health insurance or plan may require preauthorization for certain services before you receive them, except in an emergency. Preauthorization isn’t a promise your health insurance or plan will cover the cost.” Checked October 23, 2026.
16. American Occupational Therapy Association. State Occupational Therapy Licensure (licensure resource). “The ability to practice occupational therapy is regulated by state licensure agencies.” Its list of “State licensure laws and regulations” includes “Referral requirements” and “Scope of practice by state”. Checked October 23, 2026.
17. U.S. Department of Health and Human Services, Office for Civil Rights. Can health care providers, such as a specialist or hospital, to whom a patient is referred for the first time, use protected health information to set up appointments or schedule surgery or other procedures without the patient’s written consent? (HIPAA FAQ; content last reviewed January 9, 2023). Checked October 23, 2026.
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    “Yes. The HIPAA Privacy Rule does not require covered entities to obtain an individual’s consent prior to using or disclosing protected health information about him or her for treatment, payment, or health care operations.”
18. Electronic Code of Federal Regulations. 28 CFR 36.104, Definitions (ADA title III) (regulation; eCFR text up to date as of October 22, 2026; from its examples of a place of public accommodation). “insurance office, professional office of a health care provider, hospital, or other service establishment”. Checked October 23, 2026.
19. Electronic Code of Federal Regulations. 28 CFR 36.301, Eligibility criteria (ADA title III) (regulation; eCFR text up to date as of October 22, 2026). Checked October 23, 2026.
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    “A public accommodation may not impose a surcharge on a particular individual with a disability or any group of individuals with disabilities to cover the costs of measures, such as the provision of auxiliary aids”.
20. Electronic Code of Federal Regulations. 45 CFR 92.4, Definitions (Section 1557 rule) (regulation; eCFR text up to date as of October 22, 2026). “Covered entity means: (1) A recipient of Federal financial assistance;”. Checked October 23, 2026.
21. Electronic Code of Federal Regulations. 45 CFR 92.201, Meaningful access for individuals with limited English proficiency (Section 1557 rule) (regulation; eCFR text up to date as of October 22, 2026). Checked October 23, 2026.
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    “A covered entity must take reasonable steps to provide meaningful access to each individual with limited English proficiency (including companions with limited English proficiency) eligible to be served or likely to be directly affected by its health programs and activities.”; “must be provided free of charge, be accurate and timely, and protect the privacy and the independent decision-making ability of the individual with limited English proficiency”; “When interpretation services are required under this part, a covered entity must offer a qualified interpreter in its health programs and activities.”; “Require an individual with limited English proficiency to provide their own interpreter, or to pay the cost of their own interpreter”; “Rely on a minor child to interpret or facilitate communication, except as a temporary measure while finding a qualified interpreter in an emergency involving an imminent threat to the safety or welfare of an individual or the public” (the last two are among the things a covered entity “must not” do).
22. Agency for Healthcare Research and Quality. Be Easy To Reach: Tool 7 (Health Literacy Universal Precautions Toolkit, 3rd Edition; content last reviewed March 2024). Checked October 23, 2026.
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    “Some patients will hang up if the telephone system is confusing or it takes them too long to reach a person.”; “Use a ‘mystery shopper.’ Have someone in your practice act as if they were a patient, both during and after business hours.”; “Always have an option to speak to a person.”; “Create a menu with no more than five choices.”; “Use telephone interpreter services when you do not speak the caller’s language.”
23. U.S. Department of Health and Human Services, Office for Civil Rights. May providers leave messages for patients at their homes to remind them of appointments (HIPAA FAQ; content last reviewed December 28, 2022). Checked October 23, 2026.
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    “the Rule does not prohibit covered entities from leaving messages for patients on their answering machines. However, to reasonably safeguard the individual’s privacy, covered entities should take care to limit the amount of information disclosed on the answering machine. For example, a covered entity might want to consider leaving only its name and number and other information necessary to confirm an appointment, or ask the individual to call back.”; “A covered entity also may leave a message with a family member or other person who answers the phone when the patient is not home.”; “covered entities should use professional judgment to assure that such disclosures are in the best interest of the individual and limit the information disclosed”; “to receive calls at the office rather than at home are also considered to be reasonable requests, absent extenuating circumstances”.
24. Electronic Code of Federal Regulations. 45 CFR 164.522, Rights to request privacy protection for protected health information (HIPAA Privacy Rule; eCFR text up to date as of October 22, 2026). Checked October 23, 2026.
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    “A covered health care provider must permit individuals to request and must accommodate reasonable requests by individuals to receive communications of protected health information from the covered health care provider by alternative means or at alternative locations.”; “A covered health care provider may not require an explanation from the individual as to the basis for the request as a condition of providing communications on a confidential basis.”

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