Since January 2022, the No Surprises Act has required healthcare providers — including therapists — to provide Good Faith Estimates (GFEs) to uninsured and self-pay patients before services are rendered. Despite being in effect for over four years, many therapy practices still aren't fully compliant. Some therapists aren't aware of the requirement at all. Others provide incomplete estimates or miss the timing requirements.
This guide covers everything you need to know to get GFEs right.
Who Needs a Good Faith Estimate?
You must provide a GFE to any patient who:
- Is uninsured, OR
- Is not using their insurance for your services (self-pay by choice), OR
- Requests an estimate
In practice, this covers a large portion of therapy patients. Many therapists operate out-of-network, and their patients pay out of pocket and submit superbills for reimbursement. These patients are "self-pay" for GFE purposes and must receive an estimate.
What Must the GFE Include?
A Good Faith Estimate must contain:
- Patient name and date of birth
- Description of the primary service (e.g., "Individual psychotherapy, 45–60 minutes")
- Itemized list of expected charges — including your session fee and any other anticipated costs
- Diagnosis codes (ICD-10) if applicable, or a note that diagnosis will be determined at intake
- CPT codes for the services (e.g., 90834 for 45-minute individual therapy, 90837 for 60-minute)
- Service location (including telehealth indication)
- Provider name, NPI, and TIN
- Expected number of sessions over a 12-month period
- A disclaimer explaining that the estimate is not a contract, actual charges may differ, and the patient has the right to dispute charges that exceed the estimate by $400 or more
Timing Requirements
The GFE must be provided:
- For scheduled services: At least 1 business day before the service if scheduled 1–3 business days in advance, or at least 3 business days before if scheduled 10+ business days in advance.
- Upon request: Within 1 business day of a patient requesting an estimate (3 business days for a request made 10+ days before the service).
For therapy, where sessions are typically recurring, the practical approach is to provide the GFE before the first session and update it if your fees change or the treatment plan evolves significantly.
Creating a Good Faith Estimate: Step by Step
Step 1: Determine the Expected Treatment Plan
For an initial estimate, you'll need to project the expected frequency and duration of treatment. A reasonable estimate for typical outpatient therapy might be:
- Weekly sessions for the first 8–12 weeks
- Transition to biweekly for 8–12 weeks
- Then monthly or as needed
For a 12-month estimate at $175 per session, this might look like: 40 sessions x $175 = $7,000. This is an estimate, not a commitment — and the disclaimer makes that clear.
Step 2: Use the Correct Codes
Common CPT codes for therapy GFEs:
- 90791: Psychiatric diagnostic evaluation (intake session)
- 90834: Individual psychotherapy, 45 minutes
- 90837: Individual psychotherapy, 60 minutes
- 90847: Family therapy with patient present
- 90846: Family therapy without patient present
- 90853: Group psychotherapy
Step 3: Generate and Deliver the Estimate
The estimate can be delivered on paper or electronically. For modern practices, electronic delivery through a patient portal is the most efficient approach — and it creates an automatic record that the estimate was provided.
Step 4: Retain the Record
You must retain GFEs for at least 6 years. If you're using practice management software that generates GFEs, retention is automatic. If you're creating them manually, make sure they're filed with the patient's record.
What Happens If You Don't Comply?
The No Surprises Act includes enforcement provisions. While enforcement against small therapy practices has been limited so far, the regulatory framework is in place for:
- Fines of up to $10,000 per violation
- State-level enforcement actions
- Patient dispute processes that can result in reduced payments
More practically, GFEs protect you from disputes. A patient who receives a clear estimate upfront is far less likely to dispute a bill than one who's surprised by the cost after starting therapy.
Automating Good Faith Estimates
The best approach to GFE compliance is automation. When a self-pay patient books an appointment, your system should:
- Automatically generate a GFE using your standard fees and treatment templates
- Deliver it to the patient via the patient portal or email before the first session
- Record that the GFE was delivered and when
- Allow you to update the estimate if the treatment plan changes
With automated billing tools, this process takes zero manual effort — the GFE is generated and delivered as part of the intake workflow.
GFEs and Superbills
For out-of-network patients who submit superbills for reimbursement, the GFE and superbill processes are complementary. The GFE tells the patient what to expect upfront. The superbill provides the documentation they need to seek reimbursement after the session. Both should be consistent in their use of CPT codes, diagnosis codes, and fee amounts.
Best Practices
- Be transparent about your fees. The GFE is an opportunity to set expectations clearly, which strengthens the therapeutic relationship.
- Update estimates when things change. If you raise your rates or the treatment plan shifts significantly, provide an updated GFE.
- Discuss the estimate. Don't just send it — briefly explain it. Patients appreciate understanding what they're committing to financially.
- Keep it simple. The GFE doesn't need to be a complex financial document. Clear, straightforward language is better than legal jargon.
Explore Mediyn's billing features, including automated Good Faith Estimate generation for self-pay patients.