Good Faith Estimates for Therapists: What to Provide, When, and a Simple Template

If you offer self-pay services, you’ve probably heard the phrase “Good Faith Estimate” (GFE) and wondered what it actually means in real practice. The "No Surprises Act" (NSA) introduced this requirement, and the legal language can sound like it was written for massive hospital systems, not for solo clinicians seeing clients week to week.

Many therapists panic. "How can I estimate the cost of therapy? I don't know how long it will take!" This is a valid clinical point, but from a regulatory perspective, the requirement is about transparency, not prophecy. The goal is to prevent patients from receiving a $5,000 bill they didn't expect.

This guide is for mental health practices. It focuses on what you can do confidently—without overcomplicating your workflow—to comply with the law while maintaining your clinical relationship.

Who this is for

This guide is for therapists and small group practices who see uninsured clients or self-pay clients (those who have insurance but choose not to submit claims). It does not currently apply to clients using Medicare, Medicaid, or those using their insurance benefits for the service (though that may change in the future).

What you’ll walk away with

You’ll get a plain-English explanation of when a Good Faith Estimate (GFE) is required, exactly what data points must be included, a simple template you can copy, and a script for explaining it to clients without it feeling like a legal deposition.

Educational note: This is operational guidance, not legal advice. Rules and enforcement can evolve. When in doubt, consult your attorney or professional association (like CAMFT, NASW, or APA).

What a “Good Faith Estimate” is (in human terms)

A Good Faith Estimate is simply a written document that lists the expected charges for a scheduled service or item. It is the price tag. In the context of therapy, it is a document that says: "Based on what we discussed, I expect to see you weekly for 50 minutes at $150 per session. If we do this for a year, the total estimated cost is roughly $7,200."

It is not a contract; the client is not obligated to attend those sessions. It is not a promise that they will be cured. It is not a bill. It is an estimate based on the information known at the time. Its primary purpose is to allow the consumer to shop around and to prevent "sticker shock" after services are rendered.

When you must provide a GFE

CMS (Centers for Medicare & Medicaid Services) rules are specific about the timing. You must provide a GFE to an uninsured or self-pay individual in two main scenarios. First, upon scheduling: if the appointment is made at least 3 business days in advance, the GFE must be provided within 1 business day; if scheduled at least 10 business days in advance, it must be provided within 3 business days. Second, upon request: if a consumer asks for one, even if they haven't scheduled yet, you must provide it within 3 business days.

The decision tree is straightforward. If the client does not have insurance, give a GFE. If the client has insurance but chooses not to use it, give a GFE. If the client is using their insurance benefits to pay you, no GFE is required (yet).

What needs to be included

CMS provides a standard model form, but you are allowed to create your own as long as it contains the required data elements. A compliant therapy GFE must include the patient's name and date of birth, along with a description of services such as "Psychotherapy, 50 minutes" (CPT Code 90837). It needs an itemized list of services showing the expected cost per session. Diagnosis codes (ICD-10) are required; if you haven't diagnosed them yet, you can indicate "Diagnosis Pending" or "R69" (Illness, unspecified). You must also include provider information like your name, NPI, Tax ID (EIN), and office location. Finally, specific disclaimers are mandatory, stating that this is an estimate, actual charges may vary, and the client has a right to initiate a dispute if actual charges exceed the estimate by more than $400.

A simple therapist-friendly template

You can adapt this structure for your practice documentation software (like Soli, SimplePractice, etc.).

Good Faith Estimate of Expected Charges

Provider: [Your Name, Credentials] | [NPI] | [Tax ID] Date: [Date of Issue] Client: [Client Name] | [DOB]

Service: Psychotherapy (CPT 90837) Diagnosis: [Code or "Pending Evaluation"] Rate per Session: $[Your Rate] Frequency: [e.g., Weekly] Duration of Estimate: [e.g., 12 months]

Estimated Total: Based on weekly sessions for 50 weeks: 50 sessions x $[Rate] = $[Total]

Disclaimer:

• This Good Faith Estimate shows the costs of items and services that are reasonably expected for your health care needs for an item or service. The estimate is based on information known at the time the estimate was created.
• The Good Faith Estimate does not include any unknown or unexpected costs that may arise during treatment. You could be charged more if complications or special circumstances occur.
• If you are billed for more than this Good Faith Estimate, you have the right to dispute the bill. You may contact the health care provider or facility listed to let them know the billed charges are higher than the Good Faith Estimate. You can ask them to update the bill to match the Good Faith Estimate, ask to negotiate the bill, or ask if there is financial assistance available.
• You may also start a dispute resolution process with the U.S. Department of Health and Human Services (HHS). If you choose to use the dispute resolution process, you must start the dispute process within 120 calendar days (about 4 months) of the date on the original bill.
• There is a $25 fee to use the dispute process. If the agency reviewing your dispute agrees with you, you will have to pay the price on this Good Faith Estimate. If the agency disagrees with you and agrees with the health care provider or facility, you will have to pay the higher amount.

Common mistakes

One common mistake is over-promising certainty. Don't be afraid to estimate. If you aren't sure, estimate a range or a standard course, such as 12 months. You can always issue a new GFE if the frequency changes. Another mistake is being vague; you cannot just say "Sessions are $150." You must calculate the total expected cost for the period of care, for example, "Total for 12 months: $7,200." Also, failing to save proof is risky. You must keep a copy of the GFE in the client's medical record for at least 6 years. Finally, forgetting to update it is a compliance gap. If you raise your rates, or if a client switches from weekly to bi-weekly, you should issue an updated GFE to reflect the new financial reality.

Practical next steps

Start by picking a standard time window. Most therapists choose 12 months because it covers the full year and avoids having to re-issue them constantly. Next, build a template in your EHR that auto-fills the client info and your standard fee. Add the GFE as a standard part of your intake packet for all cash-pay clients. Finally, keep the conversation human. Explain that this is a form required by Congress to ensure transparency about costs upfront, clarifying that it basically says at $150 a week, a year of therapy would cost a certain amount, and that it is not a contract. This framing reduces anxiety and frames the requirement as a consumer protection rather than a bureaucratic hurdle.

The bottom line

You don’t need a legal dissertation to comply. You need a simple, repeatable estimate that supports transparency and can be generated without derailing your day. It protects your client from surprise bills, and it protects you from fee disputes.

Sources

• CMS: No Surprises Act Overview
• CMS: GFE Decision Tree
• CMS: Standard GFE Template
• APA: No Surprises Act FAQ