The No Surprises Act for Therapists
A plain-language guide to the federal Good Faith Estimate requirement: who needs one, what it must say, and what happens if a bill comes in higher than expected.
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Under Section 2799B-6 of the Public Health Service Act, you have the right to receive a Good Faith Estimate explaining how much your medical care will cost. Under the law, health care providers need to give patients who do not have insurance or who are not using insurance an estimate of the bill for medical items and services. You have the right to receive a Good Faith Estimate for the total expected cost of any non-emergency items or services. This includes related costs like medical tests, prescription drugs, equipment, and hospital fees. Make sure your health care provider gives you a Good Faith Estimate in writing at least one business day before your medical service or item. You can also ask your health care provider, and any other provider you choose, for a Good Faith Estimate before you schedule an item or service. If you receive a bill that is at least $400 more than your Good Faith Estimate, you can dispute the bill. Make sure to save a copy or picture of your Good Faith Estimate.
A Good Faith Estimate Is Not a Bill
This Good Faith Estimate is not a bill and not a contract. It shows the expected cost of the items and services listed above, based on information known at the time this estimate was created. Your actual charges may be different from this estimate if your treatment plan changes or if unforeseen items or services are needed.
The Patient-Provider Dispute Resolution Process
If your bill is at least $400 more than this Good Faith Estimate, you may be eligible to dispute the bill through the patient-provider dispute resolution (PPDR) process. You must start a dispute within 120 calendar days (about 4 months) of the date on the original bill. Starting a dispute does not affect your eligibility for other health care services in the meantime. To learn more about your right to a Good Faith Estimate and how to start a dispute, visit www.cms.gov/nosurprises.
What a Compliant Good Faith Estimate Must Include
- ✓Provider full name, practice name, and NPI
- ✓Provider Tax ID / EIN and license number
- ✓Practice address (service location) and phone number
- ✓Patient name and date of birth
- ✓Itemized CPT codes and diagnosis codes for the expected service
- ✓Expected frequency of sessions and total expected cost
- ✓A statement that the estimate is not a bill or a contract
- ✓Dispute-resolution instructions, including the $400 threshold and 120-day window
Estimate a Good Faith Estimate Total
Use the free calculator to estimate a total cost and see the $400 dispute threshold for a given fee and session count.
Try the free GFE calculatorGood Faith Estimates by Service Type
Good Faith Estimate Requirements by State
The federal requirement applies the same way in every state; state pages add your local licensing board contact.
Frequently Asked Questions
Who does the No Surprises Act Good Faith Estimate requirement apply to?
It applies to uninsured and self-pay clients. If a client is using their insurance benefits for the service, the federal GFE requirement for that service does not apply, though good practice is to still be transparent about expected costs.
What must a Good Faith Estimate include?
At minimum: the provider's name, NPI, and practice address; the expected service(s) and diagnosis codes; itemized CPT codes, fees, and expected frequency; the total expected cost; and required disclosures, including that the estimate is not a bill or a contract and information about the patient-provider dispute resolution process.
When does the estimate need to be provided?
At least one business day before the scheduled service, when the appointment is made 3 or fewer business days in advance. When scheduling further out, providers generally have more lead time, but giving the estimate as early as possible is best practice.
What happens if the actual bill is higher than the estimate?
If the final bill is at least $400 more than the Good Faith Estimate, the client may be eligible to dispute it through the patient-provider dispute resolution (PPDR) process within 120 calendar days of the bill date.
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