Guide · No Surprises Act
Good Faith Estimate for therapists: the basics
A Good Faith Estimate (GFE) is a written estimate of expected charges that providers must give uninsured or self-pay clients under the No Surprises Act rules (45 CFR 149.610). For therapists the typical case is a self-pay client in weekly sessions: one estimate can cover recurring sessions for up to 12 months.
- Who gets oneUninsured or self-pay clients
- Deadline1 or 3 business days
- Recurring sessionsOne estimate, up to 12 months
- DisputeBill $400 or more above the estimate
Who must receive a GFE
The rule covers "uninsured (or self-pay)" individuals: people without coverage, and people with coverage who choose not to submit claims for the service. In private practice that includes clients who pay out of pocket because you are out of network and they do not intend to file.
When to provide it
| Situation | Deadline |
|---|---|
| Service scheduled 3 to 9 business days ahead | Within 1 business day of scheduling |
| Service scheduled 10 or more business days ahead | Within 3 business days of scheduling |
| Client asks for an estimate | Within 3 business days of the request |
The estimate must be in writing, on paper or electronically, as the client prefers. A copy belongs in the client's record, and the regulation asks providers to make it available for six years on request.
What it must contain
Section 149.610(c) lists the required elements. In plain terms:
- Client name and date of birth.
- A description of the primary service and its expected date or period.
- An itemized list of expected services with service codes and expected charges.
- Diagnosis codes, where applicable.
- Provider name, NPI and TIN, and the location where services are provided.
- A list of services that will be scheduled separately and are not included.
- The required disclaimers: the estimate is not a contract, the client's right to dispute a bill, and where to find more information.
Recurring sessions and updates
For recurring services the regulation says the scope of an estimate "must not exceed 12 months". Issue a new one when that period ends. If the expected frequency, number of sessions or fees change, provide a new estimate; the rule sets the latest point as 1 business day before the service.
The dispute threshold
According to CMS, a self-pay client can start the patient-provider dispute resolution process if the bill is "at least $400 more than their good faith estimate", within 120 calendar days of the initial bill. CMS describes a $25 non-refundable administrative fee for the client.
Build one in your browser
Our free Good Faith Estimate builder formats the codes and fees you type into a plain-text estimate. It runs entirely in your browser, sends and stores nothing, and never suggests a code or a fee. Add the client's name, date of birth, diagnosis codes and your TIN when you give it to a client.
Frequently asked questions
Do I need a Good Faith Estimate for clients who use insurance?
Not under this rule when the client uses their insurance for the service. The GFE requirement covers uninsured clients and insured clients who choose not to file a claim.
Can one estimate cover a whole year of weekly therapy?
Yes. For recurring services the estimate can cover up to 12 months. Issue a new one when the period ends or when the expected services or fees change.
What happens if the final bill is higher than the estimate?
If the bill is at least $400 more than the estimate, CMS describes a dispute process the client can start within 120 calendar days of the bill, with a $25 fee.
Is a Good Faith Estimate a contract?
No. The required disclaimer states that the estimate is not a contract and does not require the client to obtain the services.
Do states add their own rules?
Some states have their own price transparency or estimate rules. We have not checked them state by state; check your licensing board and state law.
Sources
- 45 CFR 149.610, via Cornell Legal Information Institute, read on October 12, 2026: law.cornell.edu
- CMS: Good Faith Estimate guide for consumers: cms.gov
- CMS: Dispute a bill (uninsured or self-pay): cms.gov
- CMS: No Surprises Act resources and model notices: cms.gov/nosurprises
- Unverified State-specific estimate rules were not checked; the CMS model GFE disclaimer text was not compared word for word on October 12, 2026.
First published . Last reviewed . General information, not legal, billing or clinical advice. Check your payer contract, state rules and the cited sources before relying on it. Written by the PsyClinicAI team. Corrections: support@psyclinicai.com.