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Good Faith Estimate

A Good Faith Estimate (GFE) is a written estimate of the expected charges for scheduled care, which health care providers and facilities must give to uninsured and self-pay patients. It comes from the No Surprises Act, and the rules sit in federal regulations at 45 CFR 149.610.

For treatment centers, the estimate matters most for families paying privately, and for patients with insurance who choose not to use it. It’s also a website requirement: the regulation requires a notice of the right to a GFE to be posted where families can find it online.

That piece connects to the billing work inside our admission ops and billing practice.

This entry is general information, not legal advice. Confirm your obligations with counsel.

Key Takeaways

  • A Good Faith Estimate is required for uninsured and self-pay patients, including insured patients who don’t want a claim submitted.
  • The regulation sets deadlines: within 1 business day when care is scheduled at least 3 business days ahead, and within 3 business days when it’s scheduled 10 or more business days ahead or when the patient asks.
  • One estimate can cover recurring services like counseling, for up to 12 months.
  • A bill at least $400 above the estimate opens the federal patient-provider dispute process.
  • The notice of the right to an estimate must be on the website, in the office, and where scheduling happens.

Who gets a Good Faith Estimate

The requirement applies to uninsured individuals and to “self-pay” individuals. Under the regulation, self-pay includes someone who has coverage but doesn’t want a claim submitted to their plan, a common situation in behavioral health when families want privacy or the facility is out of network.

CMS says the requirement applies regardless of the clinical setting. Its guidance uses counseling as an example of a recurring service, so outpatient and residential behavioral health programs are both in scope when they serve self-pay patients.

People enrolled in federal health care programs, such as Medicare or Medicaid, aren’t eligible to receive a Good Faith Estimate, according to CMS’s decision tree.

Timing and what the estimate must include

The regulation treats any discussion of cost as a request. When a family asks what treatment will cost, the clock starts.

WhenDeadline
Service scheduled at least 3 business days aheadWithin 1 business day of scheduling
Service scheduled at least 10 business days aheadWithin 3 business days of scheduling
Patient requests an estimateWithin 3 business days of the request

The estimate must be written, on paper or electronically.

Required content includes the patient’s name and date of birth, a description of the primary service, an itemized list of expected items and services with service codes and expected charges, the name and identifiers of each provider or facility, and disclaimers that it’s only an estimate, isn’t a contract, and that the patient has a right to dispute.

For recurring services, CMS’s GFE guidance allows a single estimate, with a scope that can’t exceed 12 months. The estimate becomes part of the patient’s medical record.

CMS has said it’s using enforcement discretion, pending future rulemaking, on estimates that leave out expected charges from co-providers and co-facilities.

The website notice

This is the part treatment centers miss most often. The regulation requires the convening provider or facility to post a notice of the right to a Good Faith Estimate that is “prominently displayed (and easily searchable from a public search engine)” on its website, in the office, and on-site where scheduling or cost questions happen.

In practice, that means a page or clearly labeled section that a family can find from the main navigation or a search, not a PDF buried in intake paperwork. CMS publishes a model notice that providers can use, though its use isn’t required.

For a marketing team, the notice is a page like any other: it needs a findable URL, plain language, and a link from the insurance and admissions pages families already visit. Our guide to verification of benefits covers the insurance side of the same conversation.

Disputes

If the final bill is at least $400 more than the estimate for any provider or facility, the patient can start the federal patient-provider dispute resolution process within 120 calendar days of receiving the initial bill. CMS currently lists a $25 administrative fee.

While a dispute is open, the provider can’t move the disputed bill to collections. Keeping estimates accurate, and updating them when the treatment plan changes, is the simplest way to avoid disputes.

Related terms

For more on self-pay and out-of-network admissions, see our guides to the VOB-to-admit reimbursement gap, VOB vs expected reimbursement, and single case agreements before admission. For how billing fits the rest of your marketing, see the complete guide to behavioral health marketing.

Frequently Asked Questions

Do treatment centers have to give Good Faith Estimates?

Yes, for uninsured and self-pay patients. CMS says the requirement applies regardless of the clinical setting.

Self-pay includes insured patients who choose not to have a claim submitted to their plan.

Patients enrolled in federal health care programs such as Medicare and Medicaid aren’t eligible.

Does the Good Faith Estimate notice have to be on our website?

Yes. The regulation requires the notice of the right to an estimate to be prominently displayed and easily searchable from a public search engine on the website.

It must also be posted in the office and where scheduling or cost questions happen.

CMS offers a model notice that providers can use.

Can one Good Faith Estimate cover ongoing therapy?

Yes. CMS allows a single estimate for recurring services, using counseling as an example.

The scope can’t exceed 12 months.

Update the estimate if the treatment plan changes.

What happens if the bill is higher than the estimate?

If the bill is at least $400 more than the estimate for a provider or facility, the patient can start the federal dispute process within 120 days of receiving the bill.

CMS lists a $25 administrative fee.

The provider can’t send the disputed bill to collections while the dispute is open.

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