A good faith estimate is a written, itemized estimate of what a patient can expect to pay, which federal No Surprises Act rules require for uninsured and self-pay patients. Most guides to it are written for patients. This one is for the practice that has to produce it, especially a cash-pay or private-pay practice, where almost every patient is self-pay.
It covers the requirements as a checklist with the regulation cited for each, who is entitled, where insured patients stand, the official CMS form and a template to adapt. Every rule below was checked against the regulation and CMS on 8 October 2026. It is a summary of federal rules, not legal advice.
What is a good faith estimate?
The regulation, 45 CFR 149.610, defines a good faith estimate as a notification of expected charges for a scheduled or requested item or service, including the items and services reasonably expected to be provided with it. For an uninsured or self-pay patient, the expected charge is your cash-pay rate, reflecting any discount you give self-pay patients.
So what does good faith estimate mean in practice? It is your written forecast of one patient's bill, given before the care happens. It is not:
- A contract. The estimate has to say it isn't one, and that the patient doesn't have to get the services from you.
- A bill. The bill comes later, and the patient can compare the two.
- A price list. Your fees page is public. The estimate is a document for one person.
Good faith estimate requirements: a checklist
These are the duties 45 CFR 149.610 puts on the practice that schedules the care (the regulation calls it the convening provider). The paragraph is given for each, so you or your attorney can check the exact wording.
- Ask about coverage. Ask whether the patient has health coverage and, if they do, whether they want a claim submitted for this service. (149.610(b)(1)(i) and (ii))
- Tell people estimates are available. In writing on your website, in the office and wherever scheduling happens; out loud when someone books or asks about cost; and in accessible formats and the languages your patients speak. (149.610(b)(1)(iii))
- Treat any cost question as a request. Any discussion or inquiry about the potential cost of a service counts. (149.610(b)(1)(iv))
- Bring in other providers. If another provider or facility is reasonably expected to furnish services alongside yours, ask them for their part within 1 business day of the booking or request. (149.610(b)(1)(v))
- Send it on time. Within 1 business day of scheduling if the visit is at least 3 business days away, within 3 business days if it is at least 10 business days away, and within 3 business days of a request. (149.610(b)(1)(vi))
- Send a new one when the plan changes. If the expected charges, services, frequency, duration or providers change, issue a new estimate no later than 1 business day before the service. (149.610(b)(1)(vii))
- Send a new one when a request becomes a booking. An estimate given on request is followed by a new one once the service is scheduled. (149.610(b)(1)(ix))
- Cover recurring care for 12 months at most. One estimate can cover recurring visits if it sets out the timeframe, frequency and total number of visits. (149.610(b)(1)(x))
- Include the required contents. The full list is below. (149.610(c)(1))
- Deliver it in writing. On paper or electronically, whichever the patient asks for, in a form they can save and print. You can talk it through on the phone, but the written estimate is still required. (149.610(e))
- Keep it. The estimate is part of the patient's medical record, and the patient can ask for a copy of any estimate you gave them in the last 6 years. (149.610(f)(1))
- Correct mistakes quickly. An error made in good faith, with reasonable diligence, isn't by itself a failure to comply if you correct it as soon as practicable. If care happens before the fix, the patient can still dispute a bill that runs well over. (149.610(f)(3))
The rule has applied since 1 January 2022, and it doesn't change your duty to follow other state and federal laws. (149.610(g))
Who is entitled to a good faith estimate
Two groups, defined in 149.610(a)(2)(xiii):
- Uninsured: no benefits for the service under a group health plan, individual or group insurance, a federal health care program or a Federal Employees Health Benefits plan.
- Self-pay: has an employer or other group plan, individual insurance or a federal employee plan, but doesn't want a claim submitted for the service. That likely covers patients who pay you directly and plan to claim out-of-network reimbursement themselves with a superbill, although CMS's guidance doesn't address that case directly. Treat them as entitled unless your attorney says otherwise.
When a good faith estimate is due
Here is what CMS's guide to good faith estimates and the regulation say (checked 8 October 2026):
| Situation | Estimate due |
|---|---|
| Patient books 0 to 2 business days ahead | Not required |
| Self-pay patient books 3 to 9 business days ahead | Within 1 business day of booking |
| Self-pay patient books 10 or more business days ahead | Within 3 business days of booking |
| Patient asks about cost | Within 3 business days of the request |
The regulation treats any discussion or inquiry about the potential cost of a service as a request for an estimate. A price question on a free consultation call counts. CMS's fact sheet on what counts as health insurance gives emergencies and walk-in appointments as examples of care where no estimate is required.
Recurring care: one estimate for up to 12 months
For therapy, psychiatry follow-ups, memberships and programs, the regulation at 45 CFR 149.610(b)(1)(x) allows one estimate for recurring services, provided it sets out the expected scope, such as timeframes, frequency and total number of visits, and covers no more than 12 months. If the plan of care changes, issue a new one. When care runs past 12 months, issue a new estimate and tell the patient what changed from the last one.
CMS's model form suggests a line for recurring care saying the estimated costs are valid for 12 months from the date of the estimate. The template below includes it.
What a good faith estimate includes
The estimate is written, on paper or electronically, itemized, and kept with the patient's record. Under 149.610(c)(1) it has to contain:
- the patient's name and date of birth;
- a plain-language description of the main service, with its scheduled date if there is one;
- an itemized list of the services expected for the period of care, grouped by provider, with diagnosis codes where applicable, service codes and the expected charge for each;
- the name, NPI and tax ID of each provider, and the state and office location where the services will be furnished;
- a list of services you expect to be scheduled separately, before or after this period of care, with a disclaimer directly above it saying separate estimates will be issued and how to get them;
- a disclaimer that you may recommend other services as part of the patient's care that must be scheduled or requested separately and aren't in this estimate;
- a disclaimer that it is only an estimate, and that actual items, services or charges may differ;
- a disclaimer of the patient's right to dispute a bill substantially above the estimate, with instructions for where to find out how to start a dispute, and a statement that disputing won't affect the quality of their care;
- a disclaimer that it is not a contract and doesn't oblige the patient to get the services from you.
Read the regulation itself, or start from the CMS model form, and have a healthcare attorney check your version before you use it.
Do insured patients get a good faith estimate?
Not if they are using their insurance, as things stand. Here is the position as CMS gives it, checked on 8 October 2026:
- The 149.610 estimate is for uninsured and self-pay patients. A patient who wants a claim submitted to their plan isn't covered by it.
- HHS isn't enforcing the insured version yet. For patients with most commercial insurance, the No Surprises Act generally requires providers to send an estimate to the patient's plan, which the plan turns into an advanced explanation of benefits (AEOB) showing what it expects to pay and what the patient will owe. In FAQs issued in August 2021, HHS said it would defer enforcement of the provider side until rulemaking to implement it is adopted and applicable, and encouraged the states that enforce these rules to do the same. The Departments deferred enforcement of the AEOB in the same document. CMS's most recent progress update, from December 2024, says they are still working toward that rulemaking, and CMS's No Surprises rules page lists no proposed rule for it. HHS has said any rule will give providers a reasonable amount of time to comply.
- Self-pay by choice counts. A patient with an employer or other group plan, individual insurance or a federal employee plan who chooses not to have a claim submitted is self-pay, and is entitled to an estimate.
- Medicare and Medicaid are different. CMS's fact sheet on what counts as health insurance says people enrolled in federal health care programs such as Medicare and Medicaid are not entitled to a good faith estimate, even if the program doesn't cover the service or they don't want a claim submitted. If you see Medicare or Medicaid patients, ask your attorney what applies to them instead.
- Some coverage doesn't count as insurance. The same fact sheet says a patient whose only coverage is a health care sharing ministry, a farm bureau plan, a self-funded student health plan or short-term, limited-duration insurance is generally treated as uninsured, so they are entitled to an estimate.
Good faith estimate template and form
CMS publishes a model good faith estimate form (PDF), with an abbreviated version for services you won't bill for, and lists it on its No Surprises rules page. The form's instructions say HHS considers using it to be good faith compliance, and that using it is not required. CMS's sample notice says the same: you don't have to use the exact form, as long as yours includes the required information.
The CMS form has room for several providers and facilities. A private-pay practice with recurring sessions usually needs one, so here is a shorter layout with the same required elements. It is a template to adapt, not a finished form: replace everything in brackets, and have a healthcare attorney review your version before you use it.
Good faith estimate
[Practice name] · [Address] · [Phone] · [Email]
Patient: [Name] · Date of birth: [date] · Estimate issued: [date]
Service: [Plain-language description, e.g. "individual psychotherapy, weekly"] · First scheduled date: [date, or "not yet scheduled"]
Provider: [Name, credentials] · NPI: [number] · Tax ID: [EIN] · Services furnished at: [office address and state]
Expected services, [start date] to [end date, no more than 12 months]:
[Service] · Service code: [CPT] · Diagnosis code: [if applicable] · [$ per visit] × [expected number of visits] = [$]
[One line per service]
Total estimated charges: [$]. These estimated costs are valid for 12 months from the date of this estimate.
Services to be scheduled separately. Separate good faith estimates will be issued for these when they are scheduled or on request. Codes, charges and provider details will be in those estimates, not this one. To request one, contact [name, phone, email].
[Service, or "none expected"]
We may recommend other services as part of your care that must be scheduled or requested separately and are not included in this estimate.
This is only an estimate, based on the services reasonably expected when it was issued. Actual items, services or charges may differ.
If you are billed at least $400 more than this estimate, you have the right to dispute the bill through the federal patient-provider dispute resolution process. To find out how, visit www.cms.gov/nosurprises/consumers or call 1-800-985-3059. Starting a dispute will not affect the quality of care you receive from us.
This estimate is not a contract and does not require you to obtain the services from us. Keep a copy of it.
The web address and phone number in the template are the ones CMS's own model form gives patients.
What your website has to say
Part of the rule reaches your website. Under 45 CFR 149.610(b)(1)(iii), the availability of good faith estimates has to be written clearly and prominently displayed on your website, in the office and wherever scheduling or cost questions happen, easily searchable from a public search engine, given out loud when someone schedules or asks about cost, and available in accessible formats and the languages of the people scheduling with you.
CMS publishes a sample notice of the right to a good faith estimate to use as a model. Put it as text, not an image, on your fees page and your booking page. Our guide to showing prices on your website covers how the notice sits next to a price list.
A pricing page is not a good faith estimate. The page is a public price list; the estimate is a written document for one patient. The rules require the estimate and the notice. The price list is your choice, and one doesn't replace the other.
Disputes: the $400 line
Under 45 CFR 149.620, a bill is substantially in excess of the estimate when a provider's total billed charges are at least $400 more than the total expected charges that provider listed. The patient can then start the federal patient-provider dispute resolution process within 120 calendar days of receiving the initial bill. CMS's dispute page lists a $25 non-refundable fee for the patient.
For the practice, CMS's guidance for providers sets out what follows:
- you'll be asked for the estimate you gave, the bill you sent and anything that explains why the bill is higher;
- while the dispute is open, you can't move the bill into collections or threaten to, you have to pause collections already under way, you can't collect late fees, and you can't retaliate against the patient;
- if you and the patient agree a payment before a decision, you have to notify the dispute resolution entity no later than 3 business days after the settlement, and CMS's dispute page says you have to reduce the bill by at least $12.50, half the patient's fee.
The practical protection is an honest estimate: include everything you expect to charge, and issue a new estimate when the plan changes.
The No Surprises Act in one paragraph
The No Surprises Act is part of the Consolidated Appropriations Act, 2021, enacted on 27 December 2020. Since 1 January 2022, according to CMS's overview, it has protected people with health coverage from surprise bills for emergency care, for non-emergency care from out-of-network providers at in-network facilities, and for out-of-network air ambulances. For people without insurance or not using it, the Act and the rules under it created the good faith estimate and the patient-provider dispute process, which are the two parts written for a cash-pay practice's patients. CMS keeps the rules, model forms and FAQs on its No Surprises Act pages.
Make it part of booking, not an afterthought
The practices that get this right build it into the path a new patient already takes:
- The fees page and the booking page carry the notice as text.
- Intake asks the two coverage questions: do you have health coverage, and do you want a claim submitted for this care?
- Booking triggers the estimate, so the timing rules are met without anyone remembering.
- Whoever answers the phone, including your after-hours call path, treats any cost question as a request and says an estimate will follow.
- A new estimate goes out whenever the plan of care changes, and before ongoing care runs past 12 months.
Your fees page is also where your cancellation and no-show policy belongs, so write the two together; our guide to therapy cancellation policies covers that one. Done this way it is also good marketing: a patient who sees the price, the notice and a clear estimate has fewer reasons to hesitate. The glossary defines the term in one line if you need it for your own staff.
Sources
- eCFR — 45 CFR 149.610, Requirements for provision of good faith estimates of expected charges for uninsured (or self-pay) individuals, checked 8 October 2026
- eCFR — 45 CFR 149.620, Requirements for the patient-provider dispute resolution process, checked 8 October 2026
- CMS — What is a good faith health insurance estimate?, checked 8 October 2026
- CMS — What is considered "health insurance"? Determining when uninsured (or self-pay) good faith estimate rules apply (PDF), checked 8 October 2026
- CMS — Model notice: Good Faith Estimate for Health Care Items and Services, and abbreviated GFE for no-cost items or services (PDF), checked 8 October 2026
- CMS — Sample notice of uninsured (or self-pay) individual's right to receive a Good Faith Estimate (PDF), checked 8 October 2026
- CMS — Overview of No Surprises rules and fact sheets, checked 8 October 2026
- CMS — FAQs about Affordable Care Act and Consolidated Appropriations Act, 2021 implementation, Part 49, 20 August 2021 (PDF), checked 8 October 2026
- CMS — Progress toward Advanced Explanation of Benefits (AEOB) rulemaking and implementation, December 2024 update (PDF), checked 8 October 2026
- CMS — Providers: payment resolution with patients, checked 8 October 2026
- CMS — Dispute a bill, checked 8 October 2026
- CMS — Ending surprise medical bills, checked 8 October 2026