Good Faith Estimate for Therapy: No Surprises Act Compliance Guide

In this article▾

1. What is a Good Faith Estimate?
2. When must a therapist provide a Good Faith Estimate?
3. What must a Good Faith Estimate include?
4. Good Faith Estimate template for therapists
5. Does the No Surprises Act require one estimate for every provider?
6. What happens if the final bill is higher than the estimate?
7. How should a behavioral health practice operationalize GFE compliance?
8. Does a practice need to post a Good Faith Estimate notice?
9. Common Good Faith Estimate compliance mistakes
10. Frequently asked questions
11. The bottom line

Behavioral health practices generally must provide a Good Faith Estimate (GFE) of expected charges to patients who are uninsured or choose not to use their insurance for care. Under the No Surprises Act, the estimate must be provided when the patient requests one or schedules services within the applicable timeframe. It should itemize the expected services and charges, use clear language, and be delivered within the required deadline.

For cash-pay therapists, psychologists, psychiatrists, and other behavioral health providers, the GFE is both a patient financial-transparency document and an operational compliance requirement. It matters most to practices working outside insurance networks; see in-network vs. out-of-network for how that choice shapes the rest of the billing workflow.

This guide explains when a Good Faith Estimate for therapy is required, what it should contain, how to manage delivery deadlines, and what to do when the final bill is substantially higher than the estimate. It also includes an editable template practices can adapt to their workflows.

Download: Behavioral health Good Faith Estimate template (.docx)

The template is a starting point, not a certification of compliance. Review it against current federal requirements, state law, and your practice's actual services before using it.

What is a Good Faith Estimate?

A Good Faith Estimate is a written notification of the expected charges for scheduled or requested healthcare items and services. Under the No Surprises Act, the federal GFE requirements apply to uninsured individuals and people who choose not to submit a claim to their health plan for the relevant care. CMS's sample GFE explains the information the document should contain. The applicable regulation, 45 CFR § 149.610, sets out the requirements for providers and facilities.

In behavioral health, a GFE may cover expected charges for services such as:

• Individual psychotherapy.
• Family or couples therapy, where applicable.
• Group therapy.
• Psychiatric evaluation.
• Medication management.
• Other behavioral health services reasonably expected to be provided during the estimated period of care.

The estimate should reflect the services the practice reasonably expects to provide, along with their expected charges. It is not a bill, a guarantee that treatment will follow a particular course, or a substitute for other required financial disclosures.

Who needs a Good Faith Estimate?

The federal GFE requirements generally apply when a person:

• Has no applicable health coverage for the service; or
• Has coverage but chooses not to submit a claim to that coverage for the service.

That second category is particularly relevant to cash-pay and out-of-network behavioral health practices. A patient may have insurance but elect to pay privately rather than use it.

Do not assume that every patient who is out of network automatically has the same status. Confirm whether the patient intends to use insurance for the service and follow the applicable federal and state rules. Federal program coverage, including Medicare and Medicaid, has different requirements and should not be treated as interchangeable with ordinary self-pay arrangements. CMS's provider requirements page explains the scope of the No Surprises Act protections.

When must a therapist provide a Good Faith Estimate?

A provider generally must give an uninsured or self-pay patient a GFE when the patient requests one or schedules care at least three business days in advance. The deadline depends on when the service is scheduled. CMS's timing guidance describes the delivery requirements.

Business days exclude weekends and federal holidays. Practices should configure their scheduling and billing workflows around the applicable deadlines rather than relying on staff to remember them manually.

Practical rule: Treat a patient's question about the cost of care as a prompt to assess whether a GFE has been requested. The regulation directs convening providers to consider discussions or inquiries about potential costs as requests for an estimate. Do not wait for a patient to use the exact phrase "Good Faith Estimate." See 45 CFR § 149.610.

What must a Good Faith Estimate include?

The estimate should contain enough detail for the patient to understand the expected services and charges. Practices should use the current CMS sample and regulation to confirm every required field.

For a behavioral health practice, the core information typically includes the following.

1. Patient and estimate details

Include:

• Patient's full name and date of birth.
• Contact information.
• The date the estimate is prepared.
• The date or dates of the scheduled service, or an indication that the service has not yet been scheduled.
• The primary service or item requested or scheduled.
• The diagnosis and diagnosis code, if determined and applicable to the estimate.

Collect and disclose only the information necessary for the applicable requirements and the practice's legitimate workflow. Follow privacy and recordkeeping policies when handling behavioral health information.

2. Provider or practice information

Identify the provider or facility issuing the estimate. Include the applicable name, address, contact information, National Provider Identifier (NPI), and taxpayer identification information requested by the applicable form or rules.

For a group practice, make clear which legal entity and provider are associated with the estimated charges. Do not assume that a group-wide price list automatically identifies the provider responsible for every service.

3. Itemized services and expected charges

For each expected item or service, include the relevant description, service or procedure code, quantity, and expected charge, as required by the applicable rules.

For example, a therapy practice might estimate a defined number of individual psychotherapy sessions at its established self-pay rate. A psychiatric practice might list an evaluation and expected follow-up medication-management visits.

The examples should reflect the actual services reasonably expected for the estimated period of care. Do not invent a treatment plan, number of sessions, or diagnosis simply to complete a form.

4. Total expected charges

Provide the total expected charges for the services included in the estimate. Make the scope clear so the patient can understand which provider's services and fees are included.

If another provider's services are not included, do not present the estimate as the total cost of the entire course of care.

5. Required explanatory language and patient rights

Use the disclaimer and patient-rights language required by the current federal form or regulation. Explain that the estimate reflects information available when it was prepared, that unknown or unexpected services may change the final amount, and that the patient may have dispute rights if a bill is substantially higher than the estimate.

The CMS sample includes model language and is the best starting point for checking the document's required content: Sample Good Faith Estimate for Uninsured (or Self-Pay) Individuals, revised August 2023. Check the revision date before relying on a copy you downloaded previously.

Good Faith Estimate template for therapists

The editable template accompanying this article is designed for behavioral health practices that need a working document for self-pay services. It includes fields for patient information, provider details, expected services, service codes, quantities, estimated charges, total charges, separately provided services, patient rights, and delivery records.

Download the editable behavioral health GFE template (.docx)

Before deploying it:

1. Add your practice's legal name, address, contact details, and applicable provider identifiers.
2. Confirm the service descriptions, rates, codes, and expected quantities.
3. Review the patient-rights language against the current CMS sample.
4. Confirm whether other providers or facilities are reasonably expected to furnish related services and follow the applicable coordination requirements.
5. Establish a process for preparing, delivering, updating, and retaining estimates.
6. Have the responsible compliance professional or legal adviser review the final form for the practice's circumstances.

Important: An editable template is not a substitute for reviewing the current requirements. A practice should not assume that filling in the blanks alone establishes compliance.

Does the No Surprises Act require one estimate for every provider?

A Good Faith Estimate must identify the provider's expected charges for the services within the estimate's scope. Patients may need separate estimates from multiple providers or facilities involved in their care.

CMS currently explains to consumers that GFEs list expected charges for a single provider or facility, and that patients may need estimates from each provider involved. See CMS's guidance for people not using insurance.

The regulation also addresses convening providers and co-providers. Requirements concerning estimates that combine information from multiple providers have involved separate implementation guidance, so practices should check current CMS instructions rather than assuming that a single estimate from one therapist automatically covers another clinician's charges.

For a behavioral health group practice, define who issues the estimate, which services it covers, and how the patient obtains an estimate for services furnished by another entity or provider.

What happens if the final bill is higher than the estimate?

The estimate is based on the services and charges reasonably expected when it is prepared. Actual care may differ, but a significant difference can trigger patient rights under the federal dispute-resolution process.

An uninsured or self-pay patient may qualify to dispute a bill when the amount billed by a provider or facility is at least $400 more than that provider's or facility's Good Faith Estimate. The patient generally must initiate the federal process within 120 calendar days of the date on the initial bill and meet the other eligibility requirements. There is a $25 non-refundable administrative fee to start a dispute, which is deducted from what the patient owes the provider if the dispute is decided in their favor. CMS explains the eligibility requirements and process here.

This threshold applies to the relevant provider's or facility's estimate, not automatically to the combined cost of unrelated providers.

What should a practice do when a patient questions a bill?

A practice should:

• Retrieve the estimate that was provided and the final bill.
• Compare the billed services and amounts with the estimate.
• Check whether the difference reflects a service, quantity, or circumstance that was not reasonably anticipated.
• Document the review and communicate clearly with the patient.
• Follow applicable federal dispute procedures and deadlines if the patient initiates a dispute.

If a patient initiates the federal patient-provider dispute-resolution process, providers must follow the rules governing that process, including restrictions on collection activity while the dispute is pending. See CMS's provider guidance.

Do not assume that a disclaimer saying "actual charges may vary" eliminates a patient's statutory rights.

How should a behavioral health practice operationalize GFE compliance?

The most reliable process connects the estimate to scheduling, billing, and documentation. A template alone will not prevent missed deadlines or incomplete estimates.

Step 1: Identify uninsured and self-pay patients

At intake or scheduling, establish whether the patient has applicable coverage and whether they intend to use it for the service. Record the answer in the appropriate administrative workflow, alongside the rest of the intake and eligibility check.

Step 2: Capture the request or scheduling date

Record when the patient requests an estimate and when care is scheduled. These dates determine which federal delivery deadline applies.

Step 3: Generate the estimate using the expected services

Use the current fee schedule and the services reasonably expected to be furnished. Ensure the estimate reflects the correct provider, service descriptions, quantities, and expected charges. For the codes themselves, see the guide to psychotherapy CPT codes 90837, 90834 and 90832, since session length is what most often moves the expected charge.

Step 4: Deliver the estimate through the patient's preferred method

Federal guidance permits paper or electronic delivery, such as email or a patient portal. Follow the applicable requirements for the patient's preferred format and accessibility needs. Retain evidence of delivery according to your recordkeeping procedures. CMS's model notice also explains that practices must inform uninsured and self-pay individuals of their right to receive an estimate.

Step 5: Update estimates when required

If the expected scope or charges change, assess whether a new estimate is required and follow the applicable deadline. A practice should not rely on an outdated estimate when it knows that the expected services or charges have materially changed.

Step 6: Retain the estimate and connect it to billing

Keep the estimate with the patient's records and make it retrievable when preparing the final bill or responding to a question. The regulation requires the estimate to be maintained in the same manner as a medical record and provides for copies of previously issued estimates upon request. See 45 CFR § 149.610.

Does a practice need to post a Good Faith Estimate notice?

Providers and facilities subject to the federal GFE requirements must inform uninsured and self-pay individuals that estimates are available. CMS provides a model notice that can be used as a reference.

The notice requirements include making the information clearly visible in the office and at locations where scheduling or cost questions occur, making it easy to find on the practice's website, and communicating it orally when scheduling services or when patients ask about costs. Accessible formats and relevant language requirements also matter. Review CMS's sample notice of the right to receive a GFE.

A practice should check that the notice is visible, current, and consistent with the process staff actually follow. Posting a notice does not replace the obligation to provide an estimate when required.

Common Good Faith Estimate compliance mistakes

Treating every out-of-network patient as automatically self-pay

The relevant question is whether the patient is using insurance for the service. Confirm the patient's status instead of relying solely on whether the provider is in network.

Sending estimates after the deadline

A workflow that depends on someone remembering to prepare a document manually can miss deadlines. Track the request and scheduling dates and assign responsibility for timely delivery.

Providing a single session price without estimating the expected services

A rate sheet may help explain fees, but it should not be assumed to satisfy all GFE requirements. The estimate must contain the information required for the patient's requested or scheduled services. If your practice uses a sliding scale, the estimate should reflect the rate the patient will actually be charged.

Omitting applicable codes or provider identifiers

Use the current CMS sample and regulation to verify the fields that apply. Do not assume that a generic invoice or practice quote contains all required information.

Treating the estimate as a guaranteed maximum in every circumstance

The estimate describes expected charges based on the information available. Unexpected or changed services may affect the final amount, but the estimate's disclaimers do not remove applicable patient protections.

Failing to retain a copy

If a patient questions a bill, the practice needs to retrieve the estimate it issued. Build retention into the workflow rather than leaving the document in an individual employee's inbox.

Ignoring state requirements

State law may impose additional or different requirements. Practices should review the rules that apply to their location and services rather than relying exclusively on a federal template.

Frequently asked questions

Is a Good Faith Estimate required for therapy?

Generally, yes, when a patient is uninsured or chooses not to use insurance for therapy and requests an estimate or schedules services within the applicable federal timeframe. The practice should confirm the patient's status, applicable deadline, and current requirements.

Does the No Surprises Act apply to cash-pay therapists?

The federal GFE provisions generally apply to uninsured people and people who choose not to submit claims to their health plans for the relevant services. Cash-pay therapy arrangements often fall within this framework, but practices should assess the specific coverage and payment circumstances.

When must a therapist send a Good Faith Estimate?

A requested estimate generally must be provided within three business days after the request. For scheduled care, the deadline depends on how far in advance the service is scheduled: generally one business day for services scheduled 3–9 business days ahead and three business days for services scheduled 10 or more business days ahead.

Can therapists use their own Good Faith Estimate template?

Providers do not have to use the exact CMS sample form, but their document must contain the required information. Compare any customized template with the current regulation and CMS guidance before use.

Can a patient dispute a bill that is higher than the estimate?

An uninsured or self-pay patient may qualify for the federal patient-provider dispute-resolution process when a provider's or facility's bill is at least $400 higher than that provider's or facility's estimate and the other eligibility requirements are met. The patient generally must start the process within 120 calendar days of the initial bill. See the current CMS dispute guidance.

Is a Good Faith Estimate the same as a superbill?

No. A GFE communicates expected charges before care. A superbill is typically a document containing information about services already provided that a patient may use when seeking reimbursement from an insurer. One does not automatically replace the other, and a patient who submits a superbill is using their insurance, which changes whether a GFE was required in the first place.

The bottom line

For cash-pay and out-of-network behavioral health practices, Good Faith Estimate compliance starts with identifying uninsured and self-pay patients, tracking scheduling and request dates, itemizing expected services and charges, and delivering the estimate on time.

Use the editable behavioral health GFE template as a starting point, then validate it against the current CMS sample, the governing regulation, and applicable state law. Build estimate creation and retention into the practice's routine workflow so that compliance does not depend on staff remembering a deadline or recreating a document after a billing question arises.

Related: in-network vs. out-of-network, sliding-scale fees, and the behavioral health revenue cycle guide.