Good Faith Estimates for therapists, explained
Who gets a Good Faith Estimate, the ten things it must include, the deadlines, and the $400 dispute rule for self-pay therapy clients, in plain English.
A Good Faith Estimate is a written estimate of what a client will pay you before care starts. Since January 1, 2022, the No Surprises Act has required one for every client who has no insurance or isn't using it for your services. In therapy, that is most private-pay clients.
The rule is short once you strip the legal language. Give the estimate on time, include ten things, and bill within $400 of it. You can make one in two minutes with our free Good Faith Estimate generator.
Who needs a Good Faith Estimate?
Three kinds of clients, and one exception that matters in therapy.
| Client | Good Faith Estimate |
|---|---|
| No health coverage | Required |
| Has coverage, paying you directly and not filing a claim | Required |
| Has coverage and will file your superbill for reimbursement | HHS has deferred enforcement, pending further rules |
| Medicare, Medicaid, TRICARE or VA | Not covered by this rule |
A client who asks "how much will this cost?" counts as asking for an estimate, even if they never say the words.
When do you have to give it?
The deadline depends on how far ahead the first visit is scheduled.
- Scheduled at least 3 business days ahead: within 1 business day of scheduling.
- Scheduled at least 10 business days ahead: within 3 business days of scheduling.
- Client asks for one: within 3 business days of the request.
Give it in writing. Email or a client portal is fine if the client agrees to get it that way.
You also have to tell clients the estimate exists. Post a notice in your office and on your website, and mention it when a client schedules or asks about cost.
One estimate can cover up to 12 months
Weekly therapy is a recurring service, so you don't need a new estimate for every session. One estimate can list the expected number of sessions over up to 12 months. If the plan of care changes, such as moving from weekly to twice weekly, issue a new one.
The ten things a Good Faith Estimate must contain
- The client's name and date of birth.
- A plain-language description of the primary service, and the date it's scheduled if there is one.
- An itemized list of the services you expect to provide in that period, grouped by provider.
- The diagnosis codes, service codes and expected charges for each item.
- Each provider's name, NPI and tax ID.
- The state and office location where the services will happen.
- Any services you expect to schedule separately, with a note that they get their own estimate.
- A statement that other services may be recommended later and aren't on this estimate.
- A statement that it's only an estimate and actual charges may differ.
- A statement of the client's right to dispute a bill that runs at least $400 over the estimate, and where to learn how. It must also say the estimate isn't a contract and doesn't require the client to get the services from you.
The generator builds all ten into the PDF. Fill in your practice once and it stays saved in your browser.
How the $400 dispute works
If a self-pay client is billed at least $400 more than the total expected charges on your estimate, they can start the federal patient-provider dispute resolution process. They have 120 calendar days from the date on the bill to start it, and they pay a $25 administrative fee.
An independent reviewer then decides what the client owes. If you can show the extra charges came from something you couldn't reasonably have expected, the reviewer can side with you. Otherwise the client usually pays the estimated amount.
The simple way to avoid all of it: estimate the realistic number of sessions, not the minimum. A client who comes 20 times on an estimate of 12 is $1,320 over at $165 a session.
A worked example
Alex books weekly 60-minute therapy starting November 10 and pays out of pocket.
| Code | Service | Each | Qty | Expected |
|---|---|---|---|---|
| 90791 | Intake evaluation | $200 | 1 | $200 |
| 90837 | Psychotherapy, 60 minutes | $165 | 24 | $3,960 |
| Total expected charges | $4,160 |
The estimate covers 6 months. Alex can dispute a bill of $4,560 or more. That example is loaded in the generator, so you can change it to your own fees and save it.
Keep a copy
Keep every estimate you issue, and give the client a copy they can keep. Six years is the safe retention period, the same as most of your other records.
Clients who file with their plan need a superbill instead
A client who will file with their insurance needs a superbill, not an estimate. Make one with the free superbill generator, and read how to make a superbill for therapy for the fields plans require.
Sources
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