Good Faith Estimate for Therapists: What It Must Include, When to Give It, and a Template
Short answer: if a client pays you directly instead of using insurance, federal law requires you to give them a written Good Faith Estimate of what therapy will cost, within 1 to 3 business days of scheduling or of their asking. One estimate can cover up to 12 months of regular sessions, and if you bill $400 or more above it, the client can dispute the bill.
The rule comes from the No Surprises Act and is spelled out in 45 CFR 149.610. As of November 2026, the requirement for uninsured and self-pay clients is fully in effect, and the core rules for solo therapists are the same as when it started in 2022.
It's one of those requirements nobody mentions in grad school, and a lot of therapists find out about it after they've already started seeing private-pay clients. The good news: for most solo therapists, it's one form you fill out once per client per year.
Business education, not legal advice. This guide summarizes the federal rule as of November 2026. Some states add their own requirements, so check your state too.
The short version
- Who gets one: clients who are uninsured or who choose not to use insurance for therapy. That includes out-of-network clients paying you directly.
- When: within 1 business day if the first session is 3 to 9 business days away, within 3 business days if it's 10 or more away, and within 3 business days of a request.
- How long it covers: one estimate can cover up to 12 months of recurring sessions. After that, give a new one.
- The $400 rule: if your total bill is $400 or more above the estimate, the client can start a federal dispute process.
- You also have to tell people they have the right to one, on your website, in your office, and when you talk about costs.
In this guide
- Who needs a Good Faith Estimate
- When you have to give it
- What it must include
- How to estimate ongoing therapy
- The notice you have to post
- The $400 dispute rule
- What's in effect in 2026, and what isn't
- A simple template
- Frequently asked questions
Who needs a Good Faith Estimate
The Good Faith Estimate comes from the No Surprises Act, which took effect in 2022. It applies to health care providers, including therapists, counselors, social workers, psychologists, and psychiatric providers.
You owe a Good Faith Estimate to anyone who is:
- Uninsured, or
- Self-pay, meaning they have insurance but aren't using it for your services. Clients who see you out of network and pay you directly count.
You generally don't need one for clients whose sessions you bill to their insurance, Medicare, or Medicaid, because separate rules apply when a plan pays. Telehealth clients follow the same rule as in-person clients, and so do sliding scale clients: a reduced fee is still a self-pay fee.
When you have to give it
The deadline depends on how far ahead the first appointment is scheduled.
| Situation | Deadline |
|---|---|
| Scheduled at least 3 business days ahead | Within 1 business day of scheduling |
| Scheduled at least 10 business days ahead | Within 3 business days of scheduling |
| The client asks about cost (no appointment yet) | Within 3 business days of the request |
| Scheduled less than 3 business days ahead | Not required by the federal rule, but many therapists give one anyway |
Two details trip people up:
- Any question about cost counts as a request. If someone asks "how much do you charge?" on a consult call, they've asked for a Good Faith Estimate.
- It has to be in writing. You can explain it out loud, but you still have to send a written estimate, on paper or electronically, in a format the client can save and print.
What it must include
The federal rule lists what goes on the form. For a solo therapist, that means:
- The client's name and date of birth
- A plain-language description of the service (for example, "individual psychotherapy, 53 minutes")
- An itemized list of the services you expect to provide during the period, with service codes (like CPT 90791 for an initial evaluation and 90834 or 90837 for therapy), diagnosis codes if you have them, and the expected charge for each
- Your name, NPI, and tax ID, and where you'll provide services
- A list of any services that would need to be scheduled separately, with a note that those would get their own estimate
- These disclaimers:
- additional recommended services may need separate scheduling and aren't included; - the estimate is just an estimate, and actual charges may differ; - the client has the right to start a dispute if billed $400 or more above the estimate, how to do it, and that disputing won't affect their care; - the estimate isn't a contract and doesn't require them to get the services.
CMS publishes a standard Good Faith Estimate form with the required wording. Using its disclaimer language word for word is the safest approach.
How to estimate ongoing therapy
Therapy is usually recurring, and the rule allows for that. One estimate can cover up to 12 months of a recurring service, as long as it states the expected scope: how often, for how long, and how many sessions.
Here's an example for a self-pay client starting weekly therapy:
| Service | Code | Expected sessions | Fee per session | Expected total |
|---|---|---|---|---|
| Initial evaluation | 90791 | 1 | $175 | $175 |
| Psychotherapy, 53+ minutes | 90837 | 25 (weekly for about 6 months) | $150 | $3,750 |
| Total estimate | $3,925 |
Use your actual fee, not a placeholder. If you're still setting it, the therapy fee calculator works out a sustainable number first. Estimate realistically. If you're not sure how long therapy will last, estimate the period you'd reasonably expect, and give a new estimate if the plan changes. The rule also protects you if you make an honest mistake and correct it as soon as you can.
The notice you have to post
Besides the estimate itself, you have to let people know they have the right to one. The federal rule says the notice must be:
- On your website, displayed prominently and easy to find
- In your office, where scheduling and cost questions happen (if you have one)
- Said out loud when someone schedules or asks about cost
Most therapists put a short "Good Faith Estimate" notice on their FAQ or Fees page and link to CMS's consumer page. A sentence on your consult call covers the spoken part: "Since you'll be paying directly, I'll send you a Good Faith Estimate of the cost."
The $400 dispute rule
If a client's total bill from you ends up $400 or more above your estimate, they can start the federal patient-provider dispute resolution process. They must start it within 120 calendar days of the first bill and pay a $25 administrative fee. An independent reviewer then decides what the client owes.
That's the main reason accuracy matters. Practical ways to stay within your estimate:
- Base the estimate on your real fee and a realistic number of sessions.
- Include fees you know you'll charge, like an intake fee.
- Give an updated estimate when your fee or the plan changes, before you bill the higher amount.
You also have to keep each estimate in the client's record, and give a copy of any estimate from the last 6 years if the client asks.
What's in effect in 2026, and what isn't
A few parts of the No Surprises Act are still on hold, which is why therapists see conflicting advice. Here's the status as of November 2026:
| Rule | Status | What it means for a solo therapist |
|---|---|---|
| Good Faith Estimates for uninsured and self-pay clients | In effect since January 1, 2022 | Give one to every self-pay client |
| Including co-providers' charges (other clinicians involved in the same care) | Not enforced yet; HHS extended enforcement discretion pending future rules | If you work alone, this rarely applies |
| Advanced Explanation of Benefits for insured clients | Not in effect; still waiting on federal rules | No estimate is required for clients billed to insurance |
| Patient-provider dispute process ($400 or more over the estimate) | In effect | Keep estimates accurate and updated |
Federal law allows civil penalties of up to $10,000 per violation, and states can enforce the rule too. So far, most enforcement has come through patient complaints, but a missing or careless estimate is still an easy problem to avoid.
A simple template
Here's the structure for a solo therapist's Good Faith Estimate. Use CMS's standard form for the exact disclaimer wording.
- Header: your practice name, your name and license, NPI, tax ID, address, and phone
- Client: name, date of birth, and the date of the estimate
- Description: "Outpatient psychotherapy, [frequency], [session length]"
- Itemized services: a table like the one above, with codes, sessions, fees, and the total
- Separate services: "Additional services I recommend may need separate scheduling and a separate estimate."
- Disclaimers: the estimate isn't a contract, actual charges may differ, and the client's right to dispute a bill $400 or more above the estimate, with the CMS link and phone number (1-800-985-3059)
- Signature line for your records (optional)
Some states have their own cost-estimate laws on top of the federal rule. For example, Colorado has a state self-pay estimate law. Check your state's health or insurance department; the private practice by state pages link to each state's official sources.
The estimate sits naturally next to your fee policy in your intake packet. Our guide to informed consent for therapy covers the rest of that packet, including how to explain fees and cancellations.
How Well Launched helps
Your Good Faith Estimate is part of the intake paperwork step in Well Launched. The form is filled in with your practice details, NPI, fee, and the required federal disclaimers, and anything only you know is marked so you can't miss it. Your website's FAQ page also includes the required notice. If you're early in the process, the free private practice checklist shows where your paperwork fits in the order.
Frequently asked questions
Do therapists have to give Good Faith Estimates?
Yes, to clients who are uninsured or who pay you directly instead of using insurance. The No Surprises Act requirement applies to health care providers, including therapists, counselors, social workers, and psychologists.
Do I need a Good Faith Estimate for out-of-network clients?
Yes, if they're paying you directly and not using insurance for your services. Clients who pay you and submit superbills on their own are usually treated as self-pay, and most guidance recommends giving them an estimate.
How often do I need to give a new Good Faith Estimate?
At least every 12 months for ongoing therapy, and sooner if your fee or the expected treatment changes. Give the new estimate before you bill the new amount, including when a sliding scale fee goes up or down.
What happens if I charge more than the Good Faith Estimate?
If the total bill is $400 or more above the estimate, the client can start a federal dispute within 120 days of the bill, with a $25 fee. An independent reviewer decides what they owe. Small differences under $400 don't qualify.
Is there a free Good Faith Estimate template for therapists?
Yes. CMS publishes a standard Good Faith Estimate form with the required wording, and many EHRs, like SimplePractice, can generate estimates for you. Check that whichever you use includes every required element.
Do I need a Good Faith Estimate for Medicare or Medicaid clients?
Usually not, when you bill the program for their sessions. The estimate is for uninsured and self-pay clients. Medicare and Medicaid have their own rules about charging enrolled clients directly, so check those before accepting private payment from them.
Do I need to post a Good Faith Estimate notice on my website?
Yes. The federal rule requires a prominent notice of the right to a Good Faith Estimate on your website, in your office if you have one, and out loud when someone schedules or asks about cost.
Sources
- 45 CFR 149.610, requirements for Good Faith Estimates (Cornell LII)
- CMS, standard Good Faith Estimate form
- CMS, providers: payment resolution with patients
- CMS, dispute a medical bill (patient fee and 120-day window)
- CMS, patient-provider dispute resolution administrative fee guidance
- CMS, understanding costs in advance (consumer page)
- CMS, FAQs on Good Faith Estimates for uninsured or self-pay individuals (Part 3, co-provider enforcement discretion)
- CMS, No Surprises Act help desk and complaints (1-800-985-3059)
- Hall Render, "No Surprises Act enforcement begins" (penalties up to $10,000 per violation)
Get your paperwork in the right order
The free checklist shows when to set up your Good Faith Estimate, intake forms, and fees, step by step for your state. Blueprint and Launch fill in your forms with your practice details and the required wording.
Related: How to start a private practice as a therapist · What is sliding scale therapy? · Informed consent for therapy · Credentialing with insurance companies
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