This article is part of our Therapy Practice Marketing Guide: how clients find a therapist, how to market ethically and privately, and how to choose the right help. Want to know where your practice's site stands? Get a free 20–30 page website audit within 24 hours.
If you see clients who pay out of pocket, the No Surprises Act requires you to tell them they can get a Good Faith Estimate (GFE) of expected charges. You must post that information prominently on your website, in your office and where scheduling happens. Then you give a written estimate within set deadlines when someone schedules or asks.
This applies to therapists because the rule covers health care providers acting within the scope of their state license, and "self-pay" includes insured clients who choose not to use their insurance. This guide explains the website notice and the core rules, with citations to the federal regulation and CMS resources.
It is part of our Therapy Practice Marketing Guide. It is not legal advice; confirm details with a compliance advisor, and check for state rules that add to the federal ones.
Key Takeaways
- The GFE rule covers uninsured clients and insured clients who do not want a claim submitted to their plan.
- Information about GFEs must be prominently displayed on your website, in your office and where scheduling or cost questions happen.
- You must also tell people about GFEs orally when they schedule or ask about cost.
- For recurring services like weekly therapy, one estimate can cover up to 12 months.
- A client can start a federal dispute if a bill is at least $400 more than the estimate.
Who the rule covers
The rules for providers are in the federal regulation at 45 CFR 149.610. CMS's GFE and PPDR requirements slides for providers explain that, for GFE purposes, a health care provider means a physician or other health care provider "acting within the scope of practice of that provider's license or certification under applicable State law." Licensed therapists fall within that description.
The regulation defines an "uninsured (or self-pay) individual" as either:
- Someone without coverage for the service, or
- Someone who has coverage but "does not seek to have a claim for such item or service submitted" to their plan.
That second group matters for therapists. A client with insurance who pays you directly, perhaps to keep therapy off their insurance record, counts as self-pay for GFE purposes.
What your website must say
Section 149.610 says information about the availability of Good Faith Estimates must be:
- "Written in a clear and understandable manner, prominently displayed (and easily searchable from a public search engine)" on your website, in the office, and on-site where scheduling or cost questions happen.
- Given orally when scheduling or when someone asks about costs.
- Made available in accessible formats and in the languages spoken by people considering or scheduling services with you.
In website terms, that means:
- A visible notice, not a PDF buried in a footer. Many practices put a short notice on the fees page and link to it from the footer of every page.
- Crawlable text. "Easily searchable from a public search engine" means real HTML text on a page that is not blocked from search engines. An image of a notice does not meet that.
- Accessible formatting: real headings, readable contrast, and text that screen readers can read.
- Other languages if you serve clients in them.
Example website notice
Here is plain-language wording you can adapt with your compliance advisor:
> Your right to a Good Faith Estimate > Under the No Surprises Act, if you don't have insurance or you choose not to use it, you have the right to receive a Good Faith Estimate of the expected cost of your care. You can ask for one at any time, and we will give you one when you schedule. If you receive a bill that is at least $400 more than your estimate, you can dispute it. Learn more in CMS's Good Faith Estimate guide.
Make sure what the notice says matches what your intake process actually does.
Timing rules
CMS's consumer guide to the Good Faith Estimate summarizes the deadlines:
| Situation | When the estimate is due |
|---|---|
| Scheduled 0 to 2 business days ahead | No estimate required |
| Scheduled 3 to 9 business days ahead | Within 1 business day of scheduling |
| Scheduled 10 or more business days ahead | Within 3 business days of scheduling |
| Client asks before scheduling | Within 3 business days of the request |
The estimate must be given in the client's preferred form, on paper or by email. CMS says providers can also discuss it by phone or in person if the client asks.
Recurring sessions
Therapy is usually recurring, and the rule allows for that. Under 149.610, you can issue a single estimate for recurring services if it clearly states the expected scope, such as timeframes, frequency and total number of sessions, and if it covers no more than 12 months. If care will continue past 12 months, you issue a new estimate and explain what changed.
For example, an estimate might cover "weekly 50-minute individual psychotherapy sessions for up to 12 months, estimated at 48 sessions," with the per-session rate and total.
What the estimate must include
The regulation lists required contents. They include:
- The client's name and date of birth.
- A clear description of the primary service and, if applicable, the scheduled date.
- An itemized list of expected services, grouped by provider.
- Applicable diagnosis codes, expected service codes and expected charges for each item.
- The name, National Provider Identifier (NPI) and Tax Identification Number of each provider, plus the state and office location where services will be provided.
- Required disclaimers, including that other recommended services must be scheduled separately and will get their own estimates.
Because the estimate includes diagnosis codes and a date of birth, it is protected health information. Send it through your secure client portal or encrypted email, not a general marketing tool.
If your practice management software offers a GFE template, check that it includes every element in the regulation.
Disputes and record keeping
The federal patient-provider dispute process is in 45 CFR 149.620. A self-pay client can start a dispute if the total billed charges are "at least $400 more" than the expected charges on the estimate for that provider. The client has to initiate within 120 calendar days of receiving the initial bill.
CMS's consumer guide also notes that a client needs a Good Faith Estimate to dispute a bill. That is one more reason to issue them consistently.
On records, 149.610 says an issued estimate is part of the client's record, to be kept in the same way as a medical record. You must give a copy of any estimate issued in the last 6 years if the client asks.
Where to put the notice on your site
A practical layout:
- Fees page: full notice plus your rates, sliding scale policy and insurance status.
- Footer of every page: a short link, "Good Faith Estimate notice".
- Contact or booking page: one line reminding self-pay clients they can request an estimate.
- Intake paperwork: the estimate itself, delivered securely.
For more on presenting fees clearly, see Insurance vs Private Pay: How to Explain Fees. For the other notices a therapy site needs, see 7 Essential Features Every Therapy Website Needs. CMS keeps more provider materials on its provider requirements and resources page.
Next step
The GFE notice is one item on a longer pre-launch list that also covers privacy, crisis information and tracking. When you are ready, the Therapy Practice Website Launch Checklist brings it all together. To find out whether your current site's notice is visible and crawlable, get a free 20–30 page website audit within 24 hours.
Frequently asked questions
Do therapists have to give Good Faith Estimates?
Yes, for uninsured or self-pay clients. CMS materials describe providers as those acting within the scope of their state license, which includes licensed therapists. Confirm your situation with a compliance advisor.
Does the GFE apply if my client has insurance?
It applies if the client chooses not to have a claim submitted to their plan. The regulation counts them as self-pay for that service.
Where should the GFE notice go on my website?
It must be prominently displayed and easily searchable from a public search engine. A clear notice on your fees page, linked from every page's footer, is a common approach.
Can one estimate cover a year of weekly sessions?
Yes. The regulation allows a single estimate for recurring services if it states the expected scope and covers no more than 12 months.
What happens if my bill is higher than the estimate?
If the total is at least $400 more than the estimate for your services, the client can start the federal patient-provider dispute process within 120 calendar days of the initial bill.
