Good Faith Estimates for Therapists: The No Surprises Act, Explained

Do therapists have to give a Good Faith Estimate?

Yes. Under the federal No Surprises Act (in effect since January 1, 2022), health care providers must give uninsured and self-pay clients a written estimate of expected charges before care. For a private-pay or out-of-network therapy practice, that means every cash-pay client should receive a Good Faith Estimate, typically at intake.

It protects the client from surprise bills — and it protects you, because a complete, honest estimate is your record if a charge is ever questioned.

You can assemble one — with every required field and the standard CMS disclaimers — in a couple of minutes with the free Good Faith Estimate generator, which runs entirely in your browser. Confirm the output against current CMS guidance before you rely on it (see the note at the end of this article).

What has to be on it

A therapy Good Faith Estimate must include:

• Client name and date of birth.
• Provider name and credentials, National Provider Identifier (NPI), and Tax ID (TIN), plus the practice address and state.
• An itemized list of expected services, each with a CPT code, a diagnosis (ICD-10) code where one applies, the fee, and the quantity expected over the estimate period. (A diagnosis code is only required where it is needed to prepare the estimate — an initial intake or evaluation often has none yet.)
• The total expected charges and the date of the estimate.
• The required disclaimers — that it is only an estimate, that it is not a contract, and the patient-provider dispute right.

A key detail: the fee on a Good Faith Estimate is your own expected charge, not what an insurer would pay. If you use a sliding scale, the discounted fee the client will actually pay belongs on the estimate.

The $400 rule

The single most important number in the No Surprises Act for self-pay care is $400. If a client is billed $400 or more above their Good Faith Estimate for a given provider, they can dispute the difference through the federal patient-provider dispute resolution process, generally within 120 days of the bill.

That is why an honest, complete estimate matters as much for you as for the client: it sets the expectation and is your documentation if a dispute ever arises.

When to provide it

• Scheduled service: within one business day of scheduling if the appointment is at least three business days out, or within three business days if scheduled ten or more days out.
• On request: within three business days.

In practice, most solo and private-pay therapists generate one at intake and update it when the treatment plan or fee changes.

Make it part of intake, not a yearly scramble

The cleanest way to stay compliant is to generate the estimate at intake and keep a copy in the chart. The free Good Faith Estimate generator assembles every required field and disclaimer; pair it with the sliding-scale calculator for the fee, and see the rest of the free tools for private-pay therapists.

This article is for general informational purposes and is not legal advice. Confirm requirements against the current official CMS Good Faith Estimate guidance and your state rules, and consult counsel for your specific obligations.