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Is your Good Faith Estimate actually complete?
Most therapists have heard of the Good Faith Estimate. Far fewer are confident theirs would hold up — the No Surprises Act is specific about who gets one, how fast it has to arrive, and exactly what has to be on the page. Missing a required element is easy to do and easy to fix, once you can see the whole list in one place.
Work through the checklist below. Each item has a short explanation of what the requirement actually means in a therapy practice. When you're done, download the checked list as a PDF for your compliance file, or copy it as text.
One caveat, stated plainly: this is an educational checklist, not legal advice. Requirements can change and enforcement details vary — verify against current CMS guidance before you rely on any item here.
Completely private: everything runs in your browser — nothing you check is sent anywhere. Your progress is saved only on this device, so you can leave and pick up where you left off.
Every item is checked or marked as not applying — your Good Faith Estimate process covers everything on this list. Download the PDF and file it with your compliance documents.
Who needs one
No insurance at all means the No Surprises Act protections apply in full.
Insured but not using their benefits for your services counts as self-pay — a very common situation in therapy.
The offer happens when the appointment is booked, and anyone — client or prospective client — can ask for one at any time.
When it has to arrive
These are the CMS deadlines as of this writing. They can change — verify against current guidance.
The clock starts when the appointment is made, not when the session happens.
A slightly longer window applies to far-out bookings. When in doubt, sooner is always compliant.
A request alone triggers the deadline — no booking needed. Prospective clients shopping on price are entitled to one.
What has to be on it
The estimate identifies you as the provider, with both your National Provider Identifier and your Tax Identification Number.
The estimate is for a specific person, not a generic fee schedule.
When the estimate follows a booked appointment, it lists that appointment's date. An estimate provided on request, with nothing scheduled yet, won't have one — that's expected.
Your office address with the state — or, if you see the client by telehealth, a note saying so. Sessions from a home office still name the state.
"53-minute individual psychotherapy session," not just a code. The client should understand it without a decoder ring.
At intake you often won't have one yet — that's fine. Include them once a diagnosis exists.
The CPT codes for the anticipated care — for most therapists, codes like 90791, 90834, or 90837.
Your actual fee per service, in dollars, next to each item.
For ongoing therapy, that means estimating the expected number of sessions over the period the GFE covers and totaling it.
A statement that this is an estimate of expected charges — the actual services and costs may turn out to differ. The regulation names each of these four disclaimers separately, so your GFE needs each one, not a blended paragraph.
The estimate doesn't obligate the client to get the care from you. They can walk away at any point, and the GFE has to say so.
If the final bill runs at least $400 over the estimate, the client can start the federal patient–provider dispute resolution process — and the GFE must tell them that right exists.
Anything that would need to be scheduled separately isn't reflected in this estimate, and the client can ask for a separate GFE for it. Rare in a solo therapy practice, but the disclaimer is still required.
Keeping it current
One estimate can cover a whole course of recurring care — weekly therapy is exactly what this rule is about — but only up to 12 months. Care continuing past that gets a fresh GFE.
New session frequency, different services, a diagnosis that changes the picture — any change in expected scope means an updated estimate, delivered no later than 1 business day before the next appointment.
A rate change makes old estimates stale. If a raise is coming, draft the notice with our rate increase letter tool, then update every affected GFE when the new fee takes effect.
The estimate is part of the record. You'll want it if a dispute ever comes up, and it documents your compliance.
Fixing an open item
- Who needs one: add one line to your intake and scheduling scripts — every uninsured or self-pay client is offered a GFE at booking. The guide has wording you can lift.
- When it has to arrive: fold the deadline into scheduling itself — send the GFE the same day you book, and no deadline is ever close. The guide's delivery workflow walks through it.
- What has to be on it: compare your current form against CMS's model GFE notice and add the missing fields — most gaps are one line each.
- Keeping it current: tie reissues to the events that trigger them — a fee change (draft it with the rate increase letter tool), a change in expected care, or the 12-month mark on a recurring-care estimate.
The PDF opens with anything still missing, then shows each item exactly as you've marked it — checked, unchecked, or N/A — dated and suitable for filing with your compliance documents.
Want the fuller picture — templates, the recurring-care rules, and what a dispute actually looks like? Read the guide: the therapist's guide to Good Faith Estimates.
Common questions
Who needs a Good Faith Estimate?
Under the No Surprises Act, every uninsured client and every self-pay client — someone with insurance who isn’t using it for your services — is entitled to a Good Faith Estimate. You must offer one when they schedule and provide one whenever they ask, whether or not they’ve booked.
When does a Good Faith Estimate have to be delivered?
As of this writing: within 1 business day of scheduling when the appointment is booked at least 3 business days out, within 3 business days when it’s booked at least 10 business days out, and within 3 business days of any request. These deadlines come from CMS rules and can change, so verify against current CMS guidance.
What happens if I bill more than the estimate?
If the final bill comes in at least $400 above the Good Faith Estimate, the client can start the federal patient–provider dispute resolution process, and a third party reviews whether the charge stands. Your GFE must tell clients this process exists — that disclaimer is a required element, not fine print.
Do I need a new Good Faith Estimate after I change my fees?
Yes. A GFE reflects your current fees, so a rate change makes the old one stale. After any fee change takes effect, issue an updated estimate to every affected uninsured or self-pay client, and keep a copy of each version in the record.
This is an educational checklist, not legal advice. Requirements can change and enforcement details vary — verify against current CMS guidance and your own counsel before relying on it.
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