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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.
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All boxes checked — your Good Faith Estimate process covers everything on this list. Download the PDF and file it with your compliance documents.
Who needs one
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No insurance at all means the No Surprises Act protections apply in full.
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Insured but not using their benefits for your services counts as self-pay — a very common situation in therapy.
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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.
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The clock starts when the appointment is made, not when the session happens.
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A slightly longer window applies to far-out bookings. When in doubt, sooner is always compliant.
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A request alone triggers the deadline — no booking needed. Prospective clients shopping on price are entitled to one.
What has to be on it
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The estimate identifies you as the provider, with both your National Provider Identifier and your Tax Identification Number.
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The estimate is for a specific person, not a generic fee schedule.
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"53-minute individual psychotherapy session," not just a code. The client should understand it without a decoder ring.
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At intake you often won't have one yet — that's fine. Include them once a diagnosis exists.
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The CPT codes for the anticipated care — for most therapists, codes like 90791, 90834, or 90837.
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Your actual fee per service, in dollars, next to each item.
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For ongoing therapy, that means estimating the expected number of sessions over the period the GFE covers and totaling it.
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The estimate's limits — it is an estimate, not a contract — and the patient–provider dispute resolution process available if the final bill runs at least $400 over.
Keeping it current
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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.
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The estimate is part of the record. You'll want it if a dispute ever comes up, and it documents your compliance.
The PDF captures the boxes exactly as you've checked them — 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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Checklists are for catching what slipped. Practice Harbor generates Good Faith Estimates automatically, and handles the notes, scheduling, and billing around them — built by a psychologist.
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