A good faith estimate (GFE) is a written estimate of expected charges that health care providers, including therapists, must give to uninsured and self-pay clients under the No Surprises Act. The requirement took effect January 1, 2022. For therapists, a compliant GFE lists the client’s information, the expected services with their codes and fees, your NPI and Tax ID, and notices explaining that it’s only an estimate and that the client can dispute a bill that runs at least $400 over it.
This guide covers who needs a GFE, exactly what to put on it, when to deliver it, how to handle ongoing weekly therapy, how a GFE differs from a superbill, and a template you can adapt. It’s general information, not legal advice. For questions about your specific practice, talk with a health care attorney or your professional association.
What is a good faith estimate?
The No Surprises Act is a federal law aimed at reducing unexpected medical bills. One part of it requires providers to tell uninsured and self-pay patients, in advance and in writing, what they can expect to be charged. That document is the good faith estimate.
For a private-pay therapy practice, the GFE typically comes before or at the first session and covers the intake plus the expected course of ongoing sessions. It’s not a contract and doesn’t commit the client to anything. Its purpose is transparency: the client should know roughly what therapy will cost before they’re on the hook for it.
Who needs a good faith estimate?
The GFE requirement applies to clients who are:
- Uninsured, with no health coverage at all, or
- Self-pay, meaning they have coverage but aren’t asking you to submit a claim to their plan. This includes insured clients who simply choose not to use their insurance for your services.
If you’re out of network and the client pays you directly, then files their own superbill for reimbursement, you generally aren’t submitting a claim to their plan. Many practices treat these clients as self-pay and give a GFE. Check current CMS guidance if your arrangement is unusual.
Federal rules also require providers to let people know GFEs are available. In practice that means a notice on your website, in your office, and verbally when someone schedules or asks about cost. CMS publishes model notices and a model GFE form on its No Surprises Act pages. Some states have their own price-transparency rules, so check those too.
What must a good faith estimate include?
The federal rules list specific contents. Here they are in plain terms, with what each looks like in a therapy practice.
| Required element | What to write for therapy |
|---|---|
| Client name and date of birth | Exactly as in your records |
| Description of the primary service | Plain language, such as “Individual outpatient psychotherapy,” plus the scheduled date if one is set |
| Itemized list of expected services | Each service you reasonably expect to provide, such as the intake and ongoing sessions, grouped by provider |
| Service codes and expected charges | The CPT code and your fee for each item, with quantities and a total |
| Diagnosis codes, if applicable | ICD-10 codes when you have them. At first contact you may not yet. |
| Provider details | Name, NPI, and Tax ID (TIN) of each provider, and the state(s) and office location(s) where services will be provided |
| Services needing separate scheduling | Anything you expect the client to need before or after this course of care that will be scheduled separately |
| Disclaimer: possible additional services | Other services may be recommended later that must be scheduled separately and aren’t included |
| Disclaimer: it’s an estimate | The estimate isn’t a guarantee, and actual items, services, or charges may differ |
| Disclaimer: dispute rights | The client may start the patient-provider dispute resolution process if billed at least $400 more than the estimate, and where to learn how |
| Disclaimer: not a contract | The GFE isn’t a contract and doesn’t require the client to get services from you |
For telehealth practices, list the state or states where you’re licensed and expect to provide services, and the office location you practice from.
When do you have to give a good faith estimate?
Timing depends on how far ahead the service is scheduled, or whether the client asked.
| Situation | Deadline to provide the written GFE |
|---|---|
| Service scheduled at least 3 business days in advance | Within 1 business day of scheduling |
| Service scheduled at least 10 business days in advance | Within 3 business days of scheduling |
| Client requests an estimate (no appointment yet) | Within 3 business days of the request |
The GFE must be in writing, on paper or electronically, depending on how the client prefers to receive it. Many therapists simply send the GFE with intake paperwork for every new self-pay client. That covers the timing rules and keeps the process consistent. Keep a copy in the client’s record.
How do good faith estimates work for ongoing therapy?
Therapy is a recurring service, and the rules allow for that. A single GFE for recurring services can cover up to 12 months. That means you can issue one estimate at the start of care that covers the intake plus the expected number of ongoing sessions over the year.
To estimate the number of sessions, use your honest clinical expectation of frequency. For weekly therapy, a full year of sessions minus expected breaks is a reasonable basis. If you aren’t sure how long treatment will last, estimate the period you reasonably expect and state the frequency clearly.
Give an updated GFE when the picture changes: you raise your fee, the client moves from biweekly to weekly sessions, or you add a service such as family sessions. After 12 months, issue a new estimate if care continues.
Why the estimate matters. The $400 threshold is measured against what you estimated. Here’s a hypothetical example. A GFE lists 20 sessions at $150, or $3,000 in expected charges. If the client is ultimately billed $3,450 for that period, that’s $450 over the estimate, which would let them start dispute resolution. Estimating realistically, and updating when things change, protects both you and the client.
How is a good faith estimate different from a superbill?
They’re easy to confuse because both list codes and fees, but they serve different purposes.
| Good faith estimate | Superbill | |
|---|---|---|
| Purpose | Tell self-pay clients expected costs in advance | Document services already provided and paid for |
| Timing | Before or at the start of care, and when care changes | After sessions, often monthly |
| Who uses it | The client, to understand and plan for costs | The client, to seek insurance reimbursement or document HSA/FSA spending |
| Basis | No Surprises Act requirement | Standard practice for out-of-network billing |
| Amounts | Expected charges | Actual charges and payments |
Many private-pay clients get both: a GFE when they start, then superbills during treatment so they can pursue out-of-network reimbursement. The provider details on each, including NPI, Tax ID, and address, should match.
Good faith estimate template for therapists
Below is a sample layout using fictional information. Adapt it to your practice and compare it against the current CMS model form before using it.
GOOD FAITH ESTIMATE
For uninsured and self-pay clients
Date issued: 11/05/2026 Estimate period: 11/12/2026 to 11/11/2027
CLIENT
Name: Sam Rivera Date of birth: 01/15/1990
PROVIDER
Jordan Ellis, LCSW, Maple Street Counseling
100 Example Avenue, Suite 2, Anytown, ST 00000
Phone: (555) 555-0142
NPI: 1234567893 Tax ID (EIN): 12-3456789
Services provided in person at the address above and by
telehealth to clients located in: ST
PRIMARY SERVICE
Individual outpatient psychotherapy, weekly, beginning 11/12/2026
DIAGNOSIS CODE (if known): F41.1
EXPECTED SERVICES AND CHARGES (fees are hypothetical)
CPT Description Qty Fee Total
90791 Initial diagnostic evaluation 1 $200 $200
90837 Psychotherapy, about 60 minutes 48 $175 $8,400
ESTIMATED TOTAL: $8,600
SERVICES THAT MAY NEED SEPARATE SCHEDULING: None anticipated.
DISCLAIMERS
- There may be additional items or services recommended as part
of your care that must be scheduled or requested separately and
are not included in this estimate.
- This is only an estimate. Actual items, services, or charges
may differ.
- You have the right to start a dispute resolution process if
you are billed at least $400 more than this estimate. For more
information, visit cms.gov/nosurprises.
- This Good Faith Estimate is not a contract and does not require
you to obtain the services listed.
- Please save a copy of this Good Faith Estimate.A few practical notes on the template:
- Codes. The intake is commonly billed as CPT 90791, and ongoing sessions as 90834 or 90837 depending on session length. List the code you actually expect to use.
- Quantities. Use the session count you honestly expect, not the most optimistic or pessimistic number.
- Multiple services. If you also expect family sessions or a different session length, add separate lines for them.
- Consistency. Use the same NPI, Tax ID, and address you’ll put on superbills. The therapist superbill template uses the same provider fields, so you can keep them identical.
Common good faith estimate mistakes
- Leaving out NPI or Tax ID. Both are required provider details.
- Skipping the disclaimers, especially the dispute-resolution notice.
- Estimating too few sessions to make the total look lower. That increases the chance a client is billed well over the estimate.
- Never updating it. Fee increases and frequency changes call for a new GFE.
- Forgetting the availability notice on your website and in your office.
- Not keeping a copy in the client’s record.
A quick recap
Give every uninsured or self-pay client a written GFE before care starts, include all required elements and disclaimers, cover up to 12 months for ongoing therapy, and update it when services or fees change. Then, as sessions happen, give clients accurate superbills so they can document what they paid. This article is general information, not legal advice. Rules can change and state requirements vary, so confirm with CMS resources or a qualified professional.
When it’s time for the superbills that follow your estimate, the free superbill generator runs entirely in your browser. Enter your provider details once, add service lines and ICD-10 codes, and save a US Letter PDF for each client.
FAQ
Do therapists have to give a good faith estimate?
Yes, in most cases. Since January 1, 2022, the No Surprises Act has required health care providers, including therapists and other mental health clinicians, to give a written good faith estimate of expected charges to uninsured and self-pay clients. That includes clients who have insurance but choose not to use it for your services.
Do I need a good faith estimate for clients who use out-of-network benefits?
If a client pays you directly and you are not submitting a claim to their plan, many practices treat them as self-pay and give a good faith estimate. The client filing their own superbill afterward does not change the fact that you are not billing the plan. Check current CMS guidance or ask a qualified advisor if you are unsure about a particular arrangement.
How long is a good faith estimate valid for therapy?
For recurring services such as weekly therapy, a single good faith estimate can cover up to 12 months. If care continues beyond that, issue a new estimate. You should also give an updated estimate if the expected services, frequency, or fees change.
What happens if the bill is more than the good faith estimate?
If a client is billed at least $400 more than the expected charges on your good faith estimate, they can start the federal patient-provider dispute resolution process. The estimate itself must tell clients about this right and where to find information on how to use it.
Is a superbill the same as a good faith estimate?
No. A good faith estimate is given before or at the start of care and lists expected charges for self-pay clients. A superbill is an itemized record of services already provided and paid for, which clients use to seek insurance reimbursement or document HSA and FSA spending.
