Good Faith Estimates for private practice

What is a Good Faith Estimate, and why does it exist?

The Good Faith Estimate (GFE) is a written, itemized estimate of what a client can expect to pay for services. It comes from the No Surprises Act, whose purpose is price transparency — ending the era of care that arrives with an unexpected bill. For therapy, it means telling a self-pay client, up front and in writing, roughly what their treatment is expected to cost. It is nota HIPAA requirement, and it's not about privacy; it's about cost.

Who has to provide one?

The requirement centers on uninsured and self-pay clients— people who don't have insurance, or who have it but choose not to use it for your services. For private practice, that captures a lot of therapists: cash-pay practices, out-of-network providers, and anyone whose clients pay directly and seek superbills afterward. If a client isn't running the service through insurance, you generally owe them a Good Faith Estimate. "We're cash-pay, so this doesn't apply" is exactly backwards — self-pay is precisely who the rule is for.

When is the estimate due, and what must it include?

Timing is tied to scheduling and to requests. When a self-pay client schedules services — or asks for an estimate — you provide the GFE within the timeframe the rule sets, before services begin. On content, an estimate generally identifies the client and provider, describes the expected services, and gives the expected charges, along with the required diagnostic/service details. The exact line items and deadlines are specified by the regulation, so build your template from the current official requirements rather than from memory or a competitor's example.

What belongs on my website vs. my intake paperwork?

This is where practices get tangled, so keep the split clean:

• On your website: a notice that clients have the right to receive a Good Faith Estimate, placed where prospective clients actually look — usually the fees or FAQ page, and worth a line near your contact form. This is a public disclosure of the right, not the estimate itself.
• In your intake process: the personalized, itemized estimate, delivered individually to each self-pay client. It contains specifics about that person's care, so it belongs in your paperwork and records, never posted publicly.

Put simply: the website says "you have this right and here's what it means"; the intake delivers the actual numbers. The fees/FAQ page is the natural home for the notice — the same page where you state rates, which we cover in what to write on your therapy website.

How does this work for ongoing therapy?

Therapy is the awkward case for a price-estimate law: you often don't know at intake how many sessions someone will need. The GFE framework accommodates this — you can base the estimate on an expected course of care (for example, a per-session rate and an anticipated frequency or number of sessions over a period), and provide an updated estimate if the plan materially changes. The point isn't a guaranteed final total; it's an honest, good-faith projection the client can plan around, revised when reality diverges.

What are the common mistakes?

• Assuming cash-pay is exempt. Self-pay clients are the core of who the rule covers, not an exception to it.
• Skipping the posted notice. The website notice of the right is a distinct obligation from delivering individual estimates — doing one doesn't cover the other.
• Burying it in a PDF nobody opens. A notice a prospective client can't find isn't doing its job; put it in readable text where people already are.
• Confusing it with HIPAA. A secure, HIPAA-aware contact form is good practice and required for privacy — but it's a different law and doesn't satisfy the No Surprises Act.

What's the short compliance checklist?

1. Post a clear notice of the right to a Good Faith Estimate where prospective clients see it (fees/FAQ page, near the contact form).
2. Build a GFE template from the current official requirements, with the required client, provider, service, and cost fields.
3. Deliver a personalized estimate to every self-pay client within the required timeframe, before services begin.
4. For ongoing therapy, estimate an expected course of care and update it when the plan changes materially.
5. Keep the individual estimates in your records/intake — never post them publicly.
6. Confirm current federal and state guidance for your license periodically; requirements can change.

Common questions