Good Faith Estimate (No Surprises Act): Definition, Template & Example

The rule contains no annual or calendar-year trigger; the advice to re-issue annually is a simplification that happens to approximate one real rule. The actual triggers are: each new scheduling or request; any change in expected charges, services, frequency, or providers, which requires a new estimate no later than 1 business day before the affected service; and the 12-month maximum life of a recurring-services estimate, which must be replaced to continue care beyond it. Diarize each recurring estimate's expiry and your fee-change dates, and the annual myth takes care of itself.

Use the recurring-services provision: one estimate may cover a course of care for up to 12 months if it states the expected scope. Give the expected frequency, the expected number of sessions, and the charge per session, then total it. A statement like weekly 55-minute sessions from July 13, 2026 through July 12, 2027, up to 48 sessions at $180 per session, satisfies the scope requirement as CMS and the professional associations describe it. To continue past the period, issue a new estimate before the old one lapses; to change fees mid-period, issue the new estimate at least 1 business day before the first session at the new fee.

Yes. The rule defines self-pay to include insured clients who choose not to have claims submitted to their plan, which is exactly the superbill arrangement: the client pays your full fee and seeks their own out-of-network reimbursement. They are entitled to a good faith estimate before care, and the two documents then bracket each session: the GFE is pre-service and never goes to a payer, while the claim-support billing note and superbill are post-service records the client submits. Practices that equate having insurance with not needing a GFE miss this group, and it is often the largest self-pay group they have.

Not the self-pay version this page covers. When a claim will go to a plan, the statute contemplates a plan-facing estimate feeding an Advanced Explanation of Benefits, but those provisions are unenforced pending rulemaking, with the most recent federal agenda pointing at a proposed rule in 2026. Enrollees in federal programs (Medicare, Medicaid, TRICARE, VA care, FEHB plans) are excluded from the GFE entirely; for Original Medicare the analogous form is the ABN, a different instrument that does require a signature and an option choice. A Medicare beneficiary also cannot simply be relabeled self-pay for a covered service: that takes enrollment or a formal opt-out with a private contract, a path open to psychologists for years and to marriage and family therapists and mental health counselors since they became Part B providers in 2024. Requests to a plan for coverage run through a prior authorization letter, a different lane entirely.

If billed charges for you as a provider run $400 or more above your estimated total, aggregated across the estimate rather than per line item, the client may start the patient-provider dispute resolution process within 120 calendar days of the bill for a $25 fee, and a federally contracted reviewer decides what is owed. Below $400 there is no penalty mechanism at all, and the rule includes a good-faith safe harbor for errors corrected as soon as practicable. The practical defense is boring: update the estimate whenever fees or scope change, at least 1 business day before the affected session, so the bill never outruns the paper.

The rule defines the expected charge as the cash rate the client will actually be charged, reflecting any discounts, so a sliding-scale practice lists the discounted rate whenever income and family size are known. When they are not known yet, CMS's FAQ guidance from December 2022 gives the compliance path: list the undiscounted price, and attach your sliding-fee schedule so the client can see what may apply. Free and pro bono care still requires an estimate, because a $0 expectation is not a $0 guarantee; CMS created an abbreviated GFE format for providers who do not expect to bill at all.

No. The GFE is a US federal statute with no equivalent in either country, so do not import the US form as if it were required. In Canada, fee disclosure is a professional-college obligation, convention backed by college discipline rather than statute: college standards and guidelines address financial arrangements and billing, and none requires an itemized, coded written estimate. In Australia, the analogue is informed financial consent, and the bar rose on 1 December 2025, when the Psychology Board of Australia's Code of Conduct became the enforceable standard and embedded financial clarity (fees, rebates, third-party involvement, cancellation terms) in its consent expectations. In both countries the discipline is the same even though the statute is absent: document fees and payment terms in writing before treatment starts.

Yes. Give it your fee schedule, the expected frequency and duration of care, and the codes you bill, and it drafts the estimate with the plain-language service description, the recurring scope statement, and the five disclaimers in place, then checks the result against the eleven required elements before you send it. BastionGPT is HIPAA-compliant with a signed BAA on every plan, and your data is never used to train models.