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Good Faith Estimate Template for Therapists, Plus a Sample

A good faith estimate template for therapy practices with every field 45 CFR 149.610 requires, a filled-in sample, deadlines, the notice and the $400 rule.

Updated 8 min read

This good faith estimate template is written for therapy practices: one field per line, in plain words, with every element the federal rule requires. Below it you'll find a filled-in sample for an invented client, an updated estimate that shows what to change when the plan changes, the deadlines with real dates, the notice you must post on your website and in your office, how to estimate a year of weekly sessions without inviting a billing dispute, and how sliding-scale fees fit on the form.

This is the health care Good Faith Estimate under the No Surprises Act, not the mortgage form with the same name. The rule is 45 CFR 149.610, in effect since January 1, 2022. It is general information, not legal advice; the points worth taking to a health care attorney are collected near the end.

What a Good Faith Estimate is

A Good Faith Estimate (GFE) is a written estimate of what you expect to charge a client who is paying for therapy themselves. The rule defines it as "a notification of expected charges for a scheduled or requested item or service." Clients keep it, and if your bill ends up at least $400 higher than the estimate, they can ask a federal reviewer to look at the difference.

Four things are worth knowing before you fill one in:

  • It is not a contract.The client isn't agreeing to buy anything, and the form has to say so.
  • It is part of the client's record.The rule says a GFE "is considered part of the patient's medical record and must be maintained in the same manner as a patient's medical record," and you must give a client a copy of any estimate you issued in the last 6 years if they ask.
  • The expected charge is what the client will actually pay.For a self-pay client that is your cash rate "reflecting any discounts for such individuals." A sliding fee goes on the form, not your full fee.
  • CMS's forms are optional.CMS publishes a model Good Faith Estimate, and its sample notice says providers "are not required to use either exact form, as long as the form they use includes the required information." The template below is our own wording of the same required information, arranged for a therapy practice.

Who must give one

The rule applies to every licensed provider "acting within the scope of practice of that provider's license or certification under applicable State law." CMS's first set of answers on estimates says "No specific specialties, facility types, or sites of service are exempt" (CMS FAQ Part 1). Licensed counselors, social workers, marriage and family therapists and psychologists in private practice are all included.

Clients who must get one

  • Uninsured clients.People who aren't enrolled in a group health plan, individual or group health insurance, a federal health care program, or a Federal Employees Health Benefits plan. CMS adds that members of health care sharing ministries, and people with only short-term limited-duration insurance, self-funded student health plans or farm bureau plans, count as uninsured for this rule (CMS FAQ Part 5).
  • Self-pay clients.People who have private coverage or an FEHB plan but don't want a claim submitted for your sessions. Most private-pay clients of an out-of-network therapist are in this group.
  • Anyone in those groups who asks about cost.You must give an estimate on request, whether or not they book, and the rule is broad about what counts as a request: providers "shall consider any discussion or inquiry regarding the potential costs of items or services under consideration as a request for a good faith estimate." A prospective client who asks "what do you charge?" on a consultation call has asked for one.

You also have to find out who is uninsured or self-pay. The rule requires you to ask whether the person is enrolled in coverage and, if so, whether they want a claim submitted. CMS says "reasonable steps" can include asking for the name of the plan and looking at the insurance card (CMS FAQ Part 5).

Clients who don't need this estimate

  • Medicare, Medicaid and other federal program enrollees.CMS says providers "are generally not required to provide GFEs to individuals insured under Medicare, Medicaid, or other federal health care programs" (CMS FAQ Part 1). Those programs have their own billing rules.
  • Insured clients whose claim you submit.The law also foresees estimates sent to a client's plan, but HHS has deferred enforcing that part until it writes rules for it. If you bill a client's insurance for their sessions, this uninsured (or self-pay) estimate doesn't apply to them today.

Two edge cases

  • Trainees you supervise.When a licensed provider supervises an unlicensed student, CMS says "the responsibility to provide a GFE lies with the licensed provider or facility," and the estimate lists the name, NPI and TIN of the licensed provider who would bill the client (CMS FAQ Part 5).
  • Clients who pay you and send a superbill to their insurer.You aren't submitting a claim, so many practices treat these clients as self-pay and give them an estimate. The rule doesn't address this case directly; ask your attorney, and when in doubt, give the estimate.

When to send it: the deadlines

The clock depends on how far ahead the session is booked, or on when the client asked (45 CFR 149.610(b)(1)(vi)):

  • Booked 3 to 9 business days ahead:send the estimate within 1 business day of scheduling.
  • Booked at least 10 business days ahead:within 3 business days of scheduling.
  • Asked for one:within 3 business days of the request. If the client then books, they get a new estimate for the booked sessions on the scheduling deadlines above.
  • Booked fewer than 3 business days ahead:scheduling alone doesn't require an estimate (CMS FAQ Part 2). If the client also asked about cost, that is a request, and the 3-business-day request deadline still runs.

CMS counts business days as "Monday through Friday, not including federal holidays," and an estimate is on time if it goes out by 11:59 PM on the day it is due (CMS FAQ Part 5). Three examples from November 2026:

  • A client books on Monday, November 2 for Thursday, November 5. That is 3 business days ahead, so the estimate is due by 11:59 PM on Tuesday, November 3. (This matches CMS's own Monday-to-Thursday example.)
  • A client books on Monday, November 2 for Monday, November 30. That is more than 10 business days ahead, so it is due by 11:59 PM on Thursday, November 5.
  • Someone emails on Friday, November 6 to ask what you charge. Wednesday, November 11 is Veterans Day, a federal holiday, so the third business day is Thursday, November 12.

How you send it matters too. The estimate must be in writing, on paper or electronically, "pursuant to the uninsured (or self-pay) individual's requested method of delivery," and an electronic estimate must be one the client "can both save and print." If you go through the numbers on the phone, follow up in writing; the phone call alone doesn't meet the rule. CMS also asks providers not to postpone a client's care only because an estimate is late, unless the client asks to wait.

An estimate carries the client's name, date of birth and sometimes a diagnosis code, so send it the way you send other client documents. If you use email, our guide to whether Gmail is HIPAA compliant covers what that takes.

What the rule requires on every estimate

This is the list from 45 CFR 149.610(c)(1), word for word. "A good faith estimate issued to an uninsured (or self-pay) individual must include":

  • (i) "Patient name and date of birth;"
  • (ii) "Description of the primary item or service in clear and understandable language (and if applicable, the date the primary item or service is scheduled);"
  • (iii) "Itemized list of items or services, grouped by each provider or facility, reasonably expected to be furnished for the primary item or service, and items or services reasonably expected to be furnished in conjunction with the primary item or service, for that period of care including: (A) Items or services reasonably expected to be furnished by the convening provider or convening facility for the period of care; and (B) Items or services reasonably expected to be furnished by co-providers or co-facilities (as specified in paragraphs (b)(2) and (c)(2) of this section);"
  • (iv) "Applicable diagnosis codes, expected service codes, and expected charges associated with each listed item or service;"
  • (v) "Name, National Provider Identifier, and Tax Identification Number of each provider or facility represented in the good faith estimate, and the State(s) and office or facility location(s) where the items or services are expected to be furnished by such provider or facility;"
  • (vi) "List of items or services that the convening provider or convening facility anticipates will require separate scheduling and that are expected to occur before or following the expected period of care for the primary item or service. The good faith estimate must include a disclaimer directly above this list that includes the following information: Separate good faith estimates will be issued to an uninsured (or self-pay) individual upon scheduling or upon request of the listed items or services; notification that for items or services included in this list, information such as diagnosis codes, service codes, expected charges and provider or facility identifiers do not need to be included as that information will be provided in separate good faith estimates upon scheduling or upon request of such items or services; and include instructions for how an uninsured (or self-pay) individual can obtain good faith estimates for such items or services;"
  • (vii) "[Reserved]"
  • (viii) "A disclaimer that informs the uninsured (or self-pay) individual that there may be additional items or services the convening provider or convening facility recommends as part of the course of care that must be scheduled or requested separately and are not reflected in the good faith estimate;"
  • (ix) "A disclaimer that informs the uninsured (or self-pay) individual that the information provided in the good faith estimate is only an estimate regarding items or services reasonably expected to be furnished at the time the good faith estimate is issued to the uninsured (or self-pay) individual and that actual items, services, or charges may differ from the good faith estimate; and"
  • (x) "A disclaimer that informs the uninsured (or self-pay) individual of the uninsured (or self-pay) individual's right to initiate the patient-provider dispute resolution process if the actual billed charges are substantially in excess of the expected charges included in the good faith estimate, as specified in § 149.620; this disclaimer must include instructions for where an uninsured (or self-pay) individual can find information about how to initiate the patient-provider dispute resolution process and state that the initiation of the patient-provider dispute resolution process will not adversely affect the quality of health care services furnished to an uninsured (or self-pay) individual by a provider or facility; and"
  • (xi) "A disclaimer that the good faith estimate is not a contract and does not require the uninsured (or self-pay) individual to obtain the items or services from any of the providers or facilities identified in the good faith estimate."

What that means for a therapy practice:

  • You are the "convening provider." That is the provider who takes the request and schedules the main service. In solo practice there is usually no one else to include. HHS isn't currently enforcing the part that requires estimates to include charges from co-providers, pending future rules (CMS FAQ Part 3).
  • Diagnosis codes only when needed. CMS says a provider must give a diagnosis code "only where one is required for the calculation of the GFE." If you haven't assessed the client yet, as before an intake, you can leave it off. Service codes and expected charges are still required (CMS FAQ Part 2).
  • Service codes are usually CPT codes. Common ones in outpatient therapy are 90791 (diagnostic evaluation, often the intake), 90832, 90834 and 90837 (individual psychotherapy of about 30, 45 and 60 minutes; the 60-minute code means 53 minutes or more), 90847 (family or couples psychotherapy with the client present) and 90853 (group psychotherapy). Check the current CPT code set for the services you actually provide.
  • NPI and TIN are required. If you've never billed insurance and have no National Provider Identifier, you can apply through NPPES. An Employer Identification Number can serve as your Tax Identification Number, which keeps your Social Security number off client paperwork; ask your accountant if you are not sure which to use.
  • A billing contact helps. CMS "strongly encourages" an email address and phone number for someone who can speak for the practice in a billing dispute (CMS FAQ Part 4). In solo practice, that is you.

The good faith estimate template for therapy

Copy this into your word processor, fill in the brackets, and save a finished copy as a PDF so the client can save and print it. Each section maps to an element of 149.610(c)(1). Delete the items you don't expect to provide; keep every disclaimer.

Good faith estimate of expected chargesTemplate · 6 parts to fill in
GOOD FAITH ESTIMATE OF EXPECTED CHARGES[Practice name]
For clients who don't have health coverage, or whohave coverage but don't want a claim sent to it.
ABOUT THIS ESTIMATEDate of this estimate:Version: 1Replaces the estimate dated (if any):Period this estimate covers: [start date] to [end date](12 months or less)Sent by: [email / paper / other], as you asked
CLIENTClient name:Client date of birth:Authorized representative (if any):Relationship to client:
PRIMARY SERVICEWhat you are scheduling, in plain words:Date of the first scheduled session:Not yet scheduled
ONGOING SESSIONSSession type and length:How often:Number of sessions this estimate expects:Over what time frame:
PROVIDERProvider name and credentials:Practice name:National Provider Identifier (NPI):Tax Identification Number (TIN):State(s) where services will be provided:Office address:Video sessions: client's state during sessions:Contact for questions about this estimate or a bill:Name:Phone:Email:
ITEMIZED EXPECTED CHARGES FROM [PROVIDER NAME]
Item 1Service:Service code (CPT):Diagnosis code (ICD-10-CM), if needed:Quantity:Expected charge for each:Expected total for this item:
Item 2Service:Service code (CPT):Diagnosis code (ICD-10-CM), if needed:Quantity:Expected charge for each:Expected total for this item:
Item 3 (delete if not expected)Service:Service code (CPT):Diagnosis code (ICD-10-CM), if needed:Quantity:Expected charge for each:Expected total for this item:
Total expected charges from [provider name]: $Total estimated cost: $
SERVICES TO BE SCHEDULED SEPARATELYSeparate Good Faith Estimates will be given to youwhen you schedule, or ask about, any service listedbelow. Diagnosis codes, service codes, expectedcharges and provider details for these services arenot included here; they will be in those separateestimates. To get one, contact the provider namednext to the service, or ask us and we will tell youhow.
Service:Provider (if known):How to get an estimate:None expected at this time
IMPORTANT INFORMATION1. Other services. We may recommend other servicesas part of your care that must be scheduled orrequested separately. They are not included in thisestimate.
2. This is an estimate. It lists the services wereasonably expect to provide as of the date above.Actual services and charges may be different.
3. Your right to dispute a bill. If a bill from aprovider named here is at least $400 more than thatprovider's total expected charges on this estimate,you can ask the U.S. Department of Health and HumanServices to review it through the patient-providerdispute resolution process. You generally must startwithin 120 calendar days of receiving the first billwith those charges. To learn how, visitwww.cms.gov/nosurprises/consumers or call1-800-985-3059. Starting a dispute will not affectthe quality of the care you receive from us.
4. Not a contract. This estimate is not a contract.It does not require you to get services from us orfrom any provider named in it.
Please keep a copy of this estimate. You may need itif a bill is higher than the estimate.
WHAT CHANGED (updated estimates only)Previous estimate dated:What changed:Previous total:New total:

A few notes on the fields:

  • Period this estimate covers.For ongoing therapy, one estimate can cover up to 12 months (see the next section but one). Write the dates out so it is obvious when it ends.
  • Primary service in plain words."Individual therapy sessions (talk therapy), 60 minutes, weekly" is clearer to a client than a code alone.
  • Video sessions.The rule asks for the state and the location where services are furnished. For sessions by video, list your office or the state you practice from, and the state the client will be in. The rule doesn't spell out telehealth, so confirm the wording with your attorney.
  • Sent by.The rule ties delivery to the client's choice, so recording it shows you asked.

A sample good faith estimate for therapy

Everyone in this sample is invented, including the practice. The numbers marked "example" are placeholders, not real identifiers. The fees are examples, not recommendations.

Sam, an invented client, has no health insurance. He emails on Monday, November 2, 2026 and books a first session for Thursday, November 5, then weekly sessions. The estimate is due by 11:59 PM on Tuesday, November 3.

Good faith estimate of expected chargesTemplate
GOOD FAITH ESTIMATE OF EXPECTED CHARGESExample Counseling, PLLC
For clients who don't have health coverage, or whohave coverage but don't want a claim sent to it.
ABOUT THIS ESTIMATEDate of this estimate: November 3, 2026Version: 1Replaces the estimate dated (if any): nonePeriod this estimate covers: November 5, 2026 toNovember 4, 2027Sent by: email (PDF), as you asked
CLIENTClient name: Sam Ortiz (invented)Client date of birth: April 12, 1991 (invented)Authorized representative (if any): none
PRIMARY SERVICEWhat you are scheduling, in plain words: an intakesession, then individual therapy sessions (talktherapy) of 60 minutes, weekly, in the office or byvideoDate of the first scheduled session: November 5, 2026
ONGOING SESSIONSSession type and length: individual therapy, 60 minHow often: weekly, with breaks for holidays and timeawayNumber of sessions this estimate expects: 1 intakeand 44 therapy sessionsOver what time frame: November 5, 2026 toNovember 4, 2027
PROVIDERProvider name and credentials: Dana Whitlock, LPC(invented)Practice name: Example Counseling, PLLCNational Provider Identifier (NPI): 0000000000(example)Tax Identification Number (TIN): 00-0000000(example)State(s) where services will be provided: IllinoisOffice address: 100 Example Street, Suite 2,Springfield, IL (example)Video sessions: client's state during sessions:IllinoisContact for questions about this estimate or a bill:Name: Dana WhitlockPhone: (000) 000-0000 (example)Email: [email protected] (example)
ITEMIZED EXPECTED CHARGES FROM DANA WHITLOCK, LPC
Item 1Service: intake session (diagnostic evaluation)Service code (CPT): 90791Diagnosis code (ICD-10-CM), if needed: not yetdetermined; assessed at the first sessionQuantity: 1Expected charge for each: $175 (example)Expected total for this item: $175
Item 2Service: individual psychotherapy, 53 minutes or moreService code (CPT): 90837Diagnosis code (ICD-10-CM), if needed: not needed tocalculate this estimateQuantity: 44Expected charge for each: $150 (example)Expected total for this item: $6,600
Total expected charges from Dana Whitlock: $6,775Total estimated cost: $6,775
SERVICES TO BE SCHEDULED SEPARATELY(the required disclaimer, as in the template)None expected at this time
IMPORTANT INFORMATION(the four disclaimers, as in the template)
WHAT CHANGED (updated estimates only)Not applicable

Why it is built this way:

  • One estimate for the year.Weekly therapy is a recurring service, so a single estimate covers it, with the frequency, the number of sessions and the time frame spelled out. CMS names counseling as an example: "such as periodic counseling services or physical therapy services" (CMS FAQ Part 2).
  • A realistic count.Fifty-three Thursdays fall in the period. The estimate expects 44 therapy sessions because few clients attend every week of a year. Counting is the subject of the next section.
  • No diagnosis yet.Before the intake there isn't one to give, and none is needed to calculate the charges.

The same estimate, updated

In December the practice decides to raise its 60-minute fee to $160 from January 4, 2027. By then Sam will have had 6 therapy sessions at $150, leaving 38 of the 44 in his estimate. A change in expected charges calls for a new estimate no later than 1 business day before his first session at the new fee (Thursday, January 7). The new estimate is a complete form like the one above, with these lines changed:

About this estimateTemplate
ABOUT THIS ESTIMATEDate of this estimate: December 14, 2026Version: 2Replaces the estimate dated (if any): November 3,2026, for sessions from January 4, 2027Period this estimate covers: January 4, 2027 toNovember 4, 2027
Item 1Service: individual psychotherapy, 53 minutes or moreService code (CPT): 90837Quantity: 38Expected charge for each: $160 (example)Expected total for this item: $6,080
Total expected charges from Dana Whitlock: $6,080
WHAT CHANGED (updated estimates only)Previous estimate dated: November 3, 2026What changed: the fee for a 60-minute session goesfrom $150 to $160 on January 4, 2027. The number ofsessions left is the same as in the first estimate(38 of 44). The intake is finished and no longerlisted.Previous total: $6,775 (for the whole period)New total: $6,080 (for January 4 to November 4, 2027)

The rule asks you to "communicate such changes" when you deliver a new estimate, "to help patients understand what has changed." The "What changed" block does that in a few lines. Keep both versions in Sam's record. How to word a version that replaces part of an earlier period is a good question for your attorney.

How to estimate a course of therapy

Therapy rarely has a fixed length, and the rule allows for that. A single estimate can cover recurring sessions when it states "the expected scope of the recurring primary items or services (such as timeframes, frequency, and total number of recurring items or services)," and that scope "must not exceed 12 months" (45 CFR 149.610(b)(1)(x)).

Five steps

  1. Pick the period. Twelve months at most. Some therapists match it to the treatment plan review; others use 12 months for everyone and set a reminder for month 11.
  2. Write down the frequency. Weekly, every other week, or weekly for a set number of weeks and then every other week. Be specific: the client should be able to picture the schedule.
  3. Count the sessions you reasonably expect. Start from the calendar, then allow for holidays, your time off and the client's. Your own records of how long similar clients usually stay are the best guide.
  4. List everything you expect to bill in that period. The intake, ongoing sessions, and any other service you reasonably expect, such as a few family sessions, each as its own item with its code and fee.
  5. Price each item at the fee this client will pay. The rule defines the expected charge as the cash rate "reflecting any discounts." If you offer packages of sessions, price the sessions at the package rate the client is buying.

Why the count matters: the $400 math

A client can start a dispute when the total billed by a provider is at least $400 more than that provider's total expected charges on the estimate (45 CFR 149.620). At $150 a session, three sessions more than the estimate (an extra $450) are enough. The fix isn't to inflate the count, since a large total can scare off a client and the estimate is supposed to be a good faith figure. Track sessions against the estimate and send a new one before you pass it.

When to send a new estimate

The rule requires a new estimate if you anticipate "any changes to the scope of a good faith estimate (such as anticipated changes to the expected charges, items, services, frequency, recurrences, duration, providers, or facilities)," and the new one must reach the client "no later than 1 business day before the items or services are scheduled to be furnished." In a therapy practice, that usually means:

  • Your fee changes, including a yearly fee increase or a new sliding fee.
  • The frequency changes, up or down.
  • The client is likely to need more sessions than the estimate counts.
  • You add a different service, such as couples, family or longer sessions.
  • A colleague takes over the client's care.
  • The 12 months run out and therapy continues.

When you send the update, say what changed. Each estimate stays in the client's record.

The notice for your office and website

Clients have to know they can ask. The rule requires that information about the availability of a Good Faith Estimate be (45 CFR 149.610(b)(1)(iii)):

  • (A) "Written in a clear and understandable manner, prominently displayed (and easily searchable from a public search engine) on the convening provider's or convening facility's website, in the office, and on-site where scheduling or questions about the cost of items or services occur;"
  • (B) "Orally provided when scheduling an item or service or when questions about the cost of items or services occur; and"
  • (C) "Made available in accessible formats, and in the language(s) spoken by individual(s) considering or scheduling items or services with such convening provider or convening facility."

CMS publishes a model notice, "Right to Receive a Good Faith Estimate of Expected Charges", and says "HHS considers use of the model notice to be good faith compliance" with the notice requirement. Using it as published is the safest choice. If you want shorter wording for a therapy practice, this version covers the same points:

Your right to a good faith estimateTemplate
YOUR RIGHT TO A GOOD FAITH ESTIMATE
If you don't have health insurance, or you have itbut don't plan to use it for your sessions, you havethe right to a Good Faith Estimate of what your carewill cost.
You can ask us for one at any time, before or afteryou book. We will send it in writing within 3business days of your request.
If you schedule a session at least 3 business daysahead, we will send it within 1 business day ofscheduling. If you schedule at least 10 business daysahead, we will send it within 3 business days ofscheduling.
If you get a bill that is at least $400 more thanyour Good Faith Estimate, you can dispute the bill.
For questions or more information about your right toa Good Faith Estimate, visitwww.cms.gov/nosurprises/consumers, email[email protected], or call1-800-985-3059.

Where to put it:

  • Your website, as text. "Easily searchable from a public search engine" rules out a notice that exists only inside a client portal or as a picture. A short page or section in plain text, linked from your fees and booking pages, does the job. Our therapist website examples show where fees and this notice usually sit on a practice site.
  • Your office. On the wall of the waiting area, and wherever you schedule or talk about fees. If you work only by video, ask your attorney how the office part applies to you.
  • Out loud. When someone books or asks about cost, say it. For example: "Before we book, are you enrolled in any health coverage, including Medicare or Medicaid? And do you want me to bill it for these sessions? Since you'll be paying yourself, you have the right to a Good Faith Estimate of the cost. I'll email it to you by Tuesday."
  • In your paperwork. Our informed consent template includes a line telling clients they can ask for one, and the therapy intake form guide lists the estimate as part of the intake packet for clients who aren't using insurance.
  • In other languages and formats when the people contacting you need them.

The patient-provider dispute process

The dispute process is the rule's teeth, and the reason the written estimate matters. It is set out in 45 CFR 149.620 and on CMS's Dispute a medical bill and Providers: payment resolution with patients pages.

  • The threshold."Substantially in excess" means a total billed by a provider that is "at least $400 more than the total amount of expected charges listed on the good faith estimate for the provider or facility."
  • The window.The client sends a notice to HHS "postmarked within 120 calendar days of receiving the initial bill" that contains the excess charges.
  • The fee.The client pays a $25 administrative fee, according to CMS's current consumer page. If the dispute is decided in the client's favor, the $25 comes off what they owe you.
  • While it is open.You can't send the bill to collections or threaten to, must pause collections already under way, can't add late fees, and can't take any action against the client for disputing.
  • What you send.Within 10 business days of being notified, you give the reviewer (a Selected Dispute Resolution entity) a copy of the estimate, a copy of the bill and, if you have it, documentation showing the difference was for a medically necessary service caused by circumstances you couldn't reasonably have expected.
  • How it is decided.For a service listed on the estimate, if you can't show credible information of that kind, the reviewer sets the amount the client owes at the expected charge on the estimate.
  • Settling.You and the client can still agree on an amount. If you settle, you take at least half the administrative fee off the bill and notify the reviewer no later than 3 business days after the agreement.

For a therapy practice, the practical lesson is simple: disputes come from bills that drift past the estimate. An estimate that is kept current by new estimates whenever the scope changes rarely leaves a $400 gap.

Sliding-scale fees on a Good Faith Estimate

A sliding scale changes the number on the form, not the duty to give one. The expected charge is your cash rate "reflecting any discounts for such individuals," and CMS adds that the estimate "must reflect the expected charges, including any expected discounts or other relevant adjustments" (CMS FAQ Part 1).

  • If you've set the client's fee:put the sliding fee on the estimate.
  • If you haven't set it yet:CMS will treat providers that offer sliding fee discounts based on income and family size as compliant if, for a new patient whose income they don't know yet, the estimate lists at least the undiscounted price (CMS encourages attaching the sliding fee schedule), and estimates for established patients show the discounted fee (CMS FAQ Part 4). That answer is written mainly with health centers in mind; ask your attorney whether your practice can rely on it. The simplest path is to settle the fee before or at booking and estimate at that fee.
  • When the fee changes at a review:send a new estimate before the first session at the new fee, as in the update above.
  • If you see a client at no charge:CMS describes a shorter "abbreviated" estimate for providers that don't expect to bill a client, with its own disclaimers. It is in the second part of CMS's model Good Faith Estimate.

Our sliding fee schedule guide has two schedules you can copy and a client agreement that promises a new estimate whenever the fee changes.

Common mistakes

  • Waiting for a booking.A question about cost is a request. If someone asks what you charge and doesn't book, they still get an estimate within 3 business days.
  • A notice only in the intake packet.It also has to be on your website, findable by search, in your office, and said out loud.
  • Not asking about coverage.You must ask whether the person is enrolled in coverage and whether they want it billed. Write down the answer.
  • Counting too few sessions and never updating.Three sessions past the estimate at $150 each is a $450 gap.
  • Forgetting the January fee increase.A new fee for every self-pay client means a new estimate for each of them before their first session at that fee.
  • Letting the 12 months lapse.Put the end date in your calendar.
  • Dropping a disclaimer.The quality-of-care sentence and the instructions for starting a dispute are the parts most often missing.
  • Writing it as a contract.No signature line that says the client "agrees to pay." The form must say it is not a contract. A line acknowledging receipt is your choice; the rule doesn't require one.
  • A diagnosis guess before the intake.If no diagnosis is needed to calculate the estimate, leave it off.
  • No NPI or TIN.Both are required.
  • Only telling the client the numbers on the phone.The written copy is the one that counts.
  • Not keeping it.The estimate is part of the record, and clients can ask for any copy from the last 6 years.
  • A state form that misses federal items.The rule says estimates issued under state processes that don't meet it "fail to comply." Some states enforce these rules themselves, so check your state's guidance as well.

How this works in TranqBay

TranqBay doesn't change what the rule asks of you, but the booking page is where most of your estimate's numbers come from:

  • Services and fees on your booking page.You set your own services and fees: individual and couples sessions, each with its own length and fee, and packages of sessions. Use the same service names and fees on the estimate's items, and a client sees the same numbers when they book as on their estimate.
  • Confirm each booking, or let clients book straight away.If you confirm each booking yourself, make sending the estimate part of confirming. If clients book straight away, they may book at any hour, so check new bookings every business day; the 1-business-day deadline is short.
  • Payment at booking.Clients pay when they book or when you confirm their request, so each session's charge is set before it happens. Keep it matching the estimate, and when your fees change, send new estimates before the first session at the new fee.

You can see the booking page a client would use, with each service and its fee, before you write the items on your estimate.

Questions to take to a health care attorney

These are the points in this article where the rule is unclear or depends on your setup. A health care attorney in your state can answer them for your practice:

  • Whether clients who pay you and file a superbill with their insurer should get an estimate.
  • How to list the location for sessions by video, and how the office notice applies to a practice that works only online.
  • Whether a solo practice can use CMS's sliding-fee approach for new clients (FAQ Part 4).
  • How to word an updated estimate that replaces part of an earlier one.
  • Whether a no-charge consultation call needs an estimate, and if so whether the abbreviated form fits.
  • Whether to post CMS's model notice as published rather than shorter wording.
  • Whether your state has its own estimate rules or enforces the federal ones itself.

Frequently asked questions about Good Faith Estimates for therapists

Do therapists have to give a good faith estimate?

Yes, to clients who are uninsured or who have insurance but don't want it billed, when they book at least 3 business days ahead or ask about cost. The rule covers every licensed provider; CMS says no specialty is exempt.

Do I need a good faith estimate for clients using insurance?

Not this one. HHS has deferred enforcing estimates for clients who want a claim submitted to their plan. If an insured client chooses to pay you directly instead, they are self-pay and need an estimate.

Do Medicare and Medicaid clients need one?

Generally no. CMS says providers aren't required to give these estimates to people insured under Medicare, Medicaid or other federal health care programs. Those programs have their own rules about what you can charge.

Does the client have to sign the good faith estimate?

No. The rule doesn't require a signature, and the estimate must say it is not a contract. Some practices ask for an acknowledgment of receipt; if you do, word it as receipt, not agreement to pay.

Can one good faith estimate cover a year of therapy?

Yes. A single estimate can cover recurring sessions for up to 12 months if it states the time frame, frequency and total number of sessions. After 12 months, or sooner if the scope changes, issue a new one.

What if I don't have an NPI?

The estimate must include your National Provider Identifier and Tax Identification Number. If you have never billed insurance and have no NPI, you can apply through NPPES.

What happens if I don't give a good faith estimate?

The client can submit a complaint to CMS, which its consumer pages invite people to do when a provider didn't give one, and states that enforce the rule can act too. You also lose the record that protects you if a bill is questioned later.

Do I need an estimate for a no-charge consultation call?

The rule doesn't mention consultation calls. CMS describes an abbreviated estimate for services a provider doesn't expect to bill, and many practices list a no-charge consultation on the estimate as $0. Ask your attorney how your consultation fits.

How long do I keep good faith estimates?

As long as you keep the client's record, because the estimate is part of it. Clients can ask for a copy of any estimate you issued in the last 6 years.

Is this the same as a mortgage good faith estimate?

No. The mortgage Good Faith Estimate was a lender's form about loan costs. The health care Good Faith Estimate comes from the No Surprises Act and covers expected charges for health care services, including therapy.

Before your next self-pay client

  • Post the notice on your website as text, in your office, and add it to what you say when someone books or asks about cost.
  • Copy the template, fill in your practice details, NPI and TIN once, and save it as your starting file.
  • Decide how you'll count sessions for a 12-month estimate and where you'll track them.
  • Put a reminder on each client's 11th month and before any fee change.
  • Keep every version in the client's record.

If you're getting your fees and paperwork ready for a new practice, our guide to starting as a private practice therapist has the full checklist. To see where your fees would appear for clients, look at a practice website template and the booking page on practice.tranqbay.health, with each service and its fee. If you're deciding whether to join, this page explains how joining TranqBay works.

Sources

18 sources

Regulations 2CMS 15HHS 1

Updated October 25, 2026. Found it useful? Send it to a colleague.

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