Good Faith Estimate for Therapists: Essential Guide

A good faith estimate for therapists is a written estimate of expected charges that the federal No Surprises Act requires you to give clients who are uninsured or who choose to pay out of pocket instead of using insurance. Build it into your intake routine before a client asks.

Who needs a good faith estimate for therapists: the federal rule

The federal rule covers uninsured clients and self-pay clients. A self-pay client is someone who has coverage but does not plan to submit a claim to it. Per the CMS decision tree for good faith estimates, people enrolled in a federal health care program such as Medicaid, Medicare or TRICARE are not eligible, even if they do not plan to use that coverage.

Federal rule: what the estimate must include

A good faith estimate lists the items and services you expect to provide in the period of care, with the diagnosis and service codes that apply and the expected charge for each. It also carries required disclaimers and the client’s right to dispute a bill. According to CMS slides on estimates and dispute resolution, those disclaimers say that additional items may be needed, that actual charges may differ, and that the estimate is not a contract.

Federal rule: timing

Timing depends on how far ahead the visit is scheduled. These timeframes come from the CMS slides and decision tree, in business days:

• Client asks for an estimate without scheduling: send it within 3 business days of the request.
• Visit scheduled 3 to 9 business days out: send it within 1 business day of scheduling.
• Visit scheduled 10 or more business days out: send it within 3 business days of scheduling.
• Visit scheduled fewer than 3 business days out: CMS says no estimate is required.
• Scope changes: send a new estimate at least 1 business day before the service.

CMS also says a phone or in-person estimate can be given on request, but a written follow-up is required. One estimate can cover recurring services for up to 12 months, which fits weekly therapy.

Insured clients, the No Surprises Act and the part that is not in effect

The estimate for clients who plan to use insurance is a separate requirement, and CMS says it is not yet in place. CMS describes the No Surprises Act estimate requirements for people who plan to use their insurance as not yet implemented, and its toolkit says the estimate rules it describes apply only to uninsured and self-pay individuals.

The related insurer-side notice is called an advanced Explanation of Benefits. CMS’s rules and fact sheets page lists a 2022 request for information on it and two later progress documents, and it mentions no proposed or final rule. Check CMS before you change any insured-client process.

For insured clients you still verify benefits and explain the Deductible and copay. See insurance verification for therapists.

How a good faith estimate for therapists fits with out-of-network and self-pay clients

A self-pay client pays you directly. An out-of-network client may pay you and then file for reimbursement, or you may file for them. The deciding question is whether a claim goes to a payer.

If you bill an out-of-network plan on the client’s behalf, the client is using insurance, and the federal estimate requirement for self-pay does not apply on its face. If the client pays and files their own claim, ask your attorney or compliance officer how to classify them. Our guide to out-of-network billing for therapists covers the claim side, and in-network vs out-of-network credentialing covers the contract side.

The allowed amount is what a payer recognizes for a service. Your estimate is your expected charge, not an allowed amount. If you contract with a plan, balance billing rules can limit what you may collect above the allowed amount.

A simple workflow for your estimate

A workflow for a good faith estimate for therapists needs a template, a clock and a filing spot. Here is a version a solo office can run on Monday morning:

1. Template. Build one form with your NPI, TIN, expected service codes, your fee for each, and the required disclaimers.
2. Intake question. Ask every new client if they have insurance and whether they want it billed. Record the answer in the chart.
3. Clock. Note the date the client asked or scheduled, then count business days against the timing list above. Set a calendar reminder.
4. Delivery. Send the written estimate by email or mail. Mailed estimates must be postmarked by the deadline.
5. Storage. File a copy in the client record. CMS says estimates are part of the medical record and kept the same way, and that you must provide a copy of any estimate from the past 6 years on request.
6. Update. If services or frequency change, issue a new estimate before the change.

Keep the estimate aligned with what you bill. If codes or Date of Service entries drift from it, a client may dispute the bill. Your therapy superbill template is a good place to confirm codes and fees match.

What to do when a client asks about cost

When a client asks what therapy will cost, treat it as a request for a good faith estimate for therapists and answer in writing the same day if you can. CMS says any discussion of potential costs counts as a request, and the clock starts then.

Say the fee for the service, the expected frequency, and that you will send a written estimate. Then send it. If the client is insured, ask if they want you to bill the plan. If they do, route them to your normal verification and billing steps instead.

CMS also says information about estimate availability should be easy to find on your website and in your office. Have your attorney review your wording.

Does a therapist need a good faith estimate for self-pay clients?

Yes, in most cases. Under the federal rule, a therapist must give a good faith estimate to a self-pay or uninsured client who schedules a service at least 3 business days ahead or asks for an estimate, unless the client is enrolled in a federal health care program. Your attorney or compliance officer can confirm how that applies to your setting.

State law: what varies

The federal rule sets a floor, not a ceiling. The CMS toolkit says the No Surprises Act does not replace state surprise billing laws and that state protections that match or exceed the federal law generally apply. Some states may add their own rules for self-pay clients.

Those rules vary by state. Check your state Department of Insurance and licensing board websites, then ask your attorney which requirement controls.

When to ask your attorney or compliance officer

Ask counsel whenever a good faith estimate for therapists could change your exposure. This article is operational guidance, not legal advice.

• You are unsure whether a client counts as self-pay or insured.
• You see clients who file their own out-of-network claims.
• A client disputes a bill that is well above your estimate. CMS says the dispute process can open when a bill is at least $400 more than the estimate.
• You received a notice or complaint about an estimate.

Prescribers follow the same rule for self-pay medication management, listing E/M visits and add-on services. See also payer contract compliance and practice management and business tips.

How MCM South helps with good faith estimates for therapists

MCM South Medical Billing Service bills for psychotherapists and psychiatrists in ten currently served states. We help with the billing side of this topic, such as keeping codes, fees and claims consistent. Legal decisions about the estimate stay with your attorney.

Where MCM South works

MCM South works with psychotherapists and psychiatrists in ten currently served states: Georgia, Massachusetts, Connecticut, Texas, Florida, New York, Colorado, Tennessee, North Carolina and Illinois. See insurance company contacts by state, who we serve and the state billing guides. This post is operational guidance for billing, not legal advice.

The short version: good faith estimate for therapists

A good faith estimate for therapists is a written estimate of expected charges for uninsured and self-pay clients, sent on a clock tied to the scheduling date. CMS says the version for clients who plan to use insurance is not yet implemented. Build a template, track the business days, file a copy, and ask your attorney about state rules. More guides are in Resources. Make a good faith estimate for therapists part of every intake, and review your good faith estimate for therapists template each year.

Sources checked (October 29, 2026)

• CMS: Providers, payment resolution with patients
• CMS: GFE and PPDR requirements slides
• CMS: GFE decision tree
• CMS: No Surprises Act Toolkit
• CMS: Overview of rules and fact sheets

Frequently asked questions