Between now and January, many of your clients will choose a 2027 health plan. For a private-pay practice, that choice decides whether a client gets part of your fee back or pays all of it.
You can't choose a plan for them, and you shouldn't. You can tell them, before they decide, what to look for and where to find it.
The dates
- HealthCare.gov: November 1, 2026 to January 15, 2027. Enroll by December 15 for coverage that starts January 1 (CMS). States with their own exchange can set different dates.
- Medicare: October 15 to December 7, 2026 (CMS). Medicare pays differently from the plans in this guide, so this guide doesn't cover it.
- Employer plans: each employer sets its own window. A client who isn't sure when theirs is can ask HR.
What decides whether a plan pays for your sessions
The plan type. On HealthCare.gov's definitions (plan types):
- A PPO lets you see providers outside the network without a referral, for an additional cost.
- An HMO generally won't cover out-of-network care except in an emergency.
- An EPO covers services only from providers in the plan's network, except in an emergency.
- A POS plan charges less in network and requires a referral from a primary care doctor to see a specialist. Whether it pays out of network depends on the plan.
For a client who wants to keep seeing you and claim part of the fee, that usually means a PPO, or a POS plan that lists out-of-network benefits.
The out-of-network deductible and coinsurance. Clients pay their deductible before the plan starts to pay, then a percentage of each session, the coinsurance (deductible, out-of-network coinsurance). Plans list separate figures for out-of-network care, and those are the ones that matter here.
The allowed amount. The plan pays its percentage of the amount it allows for a session, which can be less than your fee, and the client owes the difference (allowed amount). An example with made-up numbers: your fee is $160, the plan allows $120, and out-of-network coinsurance is 40%. Once the deductible is met, the plan pays $72 and the client's cost is $88.
The out-of-pocket maximum. HealthCare.gov's glossary describes the out-of-pocket maximum as covering in-network care, and for high-deductible plans the IRS says the limit doesn't apply to out-of-network expenses (IRS Publication 969). Clients shouldn't count on out-of-network sessions stopping at that cap.
Where to find all of this. Every plan has to give a free Summary of Benefits and Coverage (29 CFR 2590.715-2715), which lists the out-of-network deductible and coinsurance. For employer plans, the Summary Plan Description explains how and where to file a claim (Department of Labor). Filing deadlines vary by plan, so that document is where to check.
HSA and FSA money
Clients can pay you from a health savings account or flexible spending account when the therapy is medical treatment. IRS Publication 502 includes amounts paid to a psychologist for medical care, for psychiatric care and for "therapy received as medical treatment" (IRS Publication 502), and HSAs and FSAs generally follow that list. It excludes expenses that are "merely beneficial to general health," so don't promise eligibility for coaching or anything that isn't treatment.
The 2027 numbers:
- HSA: $4,500 for self-only coverage and $9,000 for family coverage (IRS Rev. Proc. 2026-24).
- FSA: the 2027 limit hadn't been published as of October 30, 2026. For 2026 it is $3,400, and if the employer's plan allows carryover, up to $680 can carry into 2027 (IRS Rev. Proc. 2025-32).
Open enrollment is also when clients set their FSA amount for the year, so it helps them to know roughly what a year of sessions costs.
Two things clients should know before they file
A claim carries a diagnosis. To be reimbursed, a claim lists the client's diagnosis code (NUCC 1500 instructions, item 21). That goes to the insurer. Some clients pay privately because they would rather it didn't, and they should get to make that choice knowing it.
Good Faith Estimates still apply. The No Surprises Act rule covers clients who have insurance but don't ask to have a claim sent to it (45 CFR 149.610). Official guidance doesn't address clients who file their own superbills, so giving them an estimate when they schedule is the cautious choice. Our Good Faith Estimate guide and free generator cover how.
An email you can send
Adapt the wording and fee to your practice. It explains how benefits work without telling anyone which plan to buy.
Subject: Open enrollment and your sessions
Hi [name],
If you're choosing a health plan for 2027, it may affect what you pay for our sessions. I'm out of network with insurance plans, so whether you get part of my fee back depends on your plan's out-of-network benefits.
If that matters to you, a few things to check on any plan you're considering:
- Does it cover out-of-network outpatient mental health care, including telehealth? (PPO plans usually do. HMO and EPO plans usually don't.)
- What is the out-of-network deductible, and the out-of-network coinsurance?
- What is the allowed amount for a 60-minute session (code 90837) or a 45-minute session (code 90834)?
- How do I submit a superbill, and what is the deadline?
The plan's Summary of Benefits and Coverage answers most of these, and the plan's member services line can answer the rest.
If you have an FSA or HSA, therapy can usually be paid from it. I'm happy to give you a yearly estimate of your sessions to help you plan.
[Your name]
For the conversation in session, our guide to explaining out-of-network benefits has a script and what to avoid saying.
Have superbills ready in January
When the new plan year starts, clients who chose out-of-network coverage will ask for superbills. Insurers set their own requirements, and a superbill usually includes your NPI, the client's diagnosis code, the session codes, dates and fees, and what the client paid.
In CoralEHR, superbills take one click, with the diagnosis carried over by date of service, and Good Faith Estimates for self-pay clients are issued at booking. Out-of-network claims that Coral files for clients are coming to Pro.
Sources: CMS, Affordable Care Act basics for plan year 2027 · CMS, 2027 Medicare Advantage and Part D fact sheets · HealthCare.gov, plan types · HealthCare.gov glossary · IRS Publication 502 · IRS Publication 969 · IRS Rev. Proc. 2026-24 · IRS Rev. Proc. 2025-32 · 29 CFR 2590.715-2715 · Department of Labor, filing a claim · 45 CFR 149.610 · NUCC 1500 claim form instructions
Read on October 30, 2026. Plans and limits change. Clients should confirm their own benefits with their plan.
Frequently Asked Questions
When is open enrollment for 2027 health plans?
On HealthCare.gov, November 1, 2026 to January 15, 2027. Enroll by December 15 for coverage that starts January 1. Medicare open enrollment runs October 15 to December 7, 2026. Employer plans and state exchanges set their own dates.
Which health plans pay for out-of-network therapy?
PPO plans cover providers outside the network without a referral, at a higher cost to the client. HMO and EPO plans generally don't cover out-of-network care except in an emergency. For any plan, the Summary of Benefits and Coverage shows the out-of-network deductible and coinsurance.
Can clients use an HSA or FSA to pay a private-pay therapist?
Yes, when the therapy is medical treatment. IRS Publication 502 includes amounts paid to a psychologist for medical care, for psychiatric care and for therapy received as medical treatment, and HSAs and FSAs generally follow that list.
What are the 2027 HSA limits?
$4,500 for self-only coverage and $9,000 for family coverage (IRS Rev. Proc. 2026-24). The 2027 FSA limit hadn't been published as of October 30, 2026. For 2026 it is $3,400, with up to $680 carried into 2027 if the employer's plan allows carryover.
Arhaan Gupta
Co-founder and CEO, CoralEHR
I co-founded CoralEHR, an EHR for private-pay therapy practices, and I set up every new practice with them myself.
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