If you see uninsured or self-pay clients, you're legally required to give them a Good Faith Estimate (GFE) before services begin. The No Surprises Act made this a federal requirement starting January 1, 2022 - and having a solid template is one of the easiest ways to stay compliant without adding stress to your intake process.

Key Takeaways

• The No Surprises Act requires therapists to provide a GFE to all uninsured and self-pay clients before or at the time services are scheduled - and applies to all licensed healthcare providers, including therapists, counselors, psychologists, and psychiatrists.

• A compliant GFE template must include your provider details, expected CPT codes, diagnosis codes, session frequency, total cost estimate, and a summary of client dispute rights - missing any of these puts you out of compliance.

• Using a standardized template makes intake smoother, reduces compliance risk, and builds trust with clients before the first session even starts.

What Is a Good Faith Estimate in Therapy?

A Good Faith Estimate is a written document you give clients that lays out what they can expect to pay for your services. It isn't a binding contract - costs can shift - but it gives clients a clear picture of anticipated expenses before they commit to care.

For therapists, this matters because many clients come to you without insurance or choose not to use it. Without a GFE, those clients have no way of knowing what they're walking into financially. The GFE fixes that problem before it starts.

The No Surprises Act: What Therapists Need to Know

The No Surprises Act was enacted as part of the Consolidated Appropriations Act of 2020 and took effect January 1, 2022. It was designed to protect patients from unexpected medical bills - and its requirements extend to outpatient mental health services.

Under the law, if a client's final bill exceeds your estimate by $400 or more, they have the right to dispute it through a patient-provider dispute resolution process. According to the American Psychological Association, the main practical risk to clinicians comes from exactly that scenario - actual costs running ahead of an outdated or incomplete GFE.

Who Is Required to Provide a GFE?

You're required to provide a GFE for any client who is uninsured or who chooses not to use their insurance - even if they have coverage but prefer to pay out of pocket. This applies whether you're a solo practitioner or part of a group practice.

Timing matters too. According to the American Psychiatric Association's implementation guidance, if a service is scheduled at least three business days in advance, the GFE must be delivered no later than one business day after scheduling. For appointments scheduled 10 or more days out, you have up to three business days to provide it.

What to Include in Your GFE Template

Getting the components right is what separates a compliant GFE from a compliance gap. According to requirements published by the American Academy of Marriage and Family Therapists based on CMS guidance, your GFE must include the following:

Provider and Practice Information

• Your full legal name and practice name

• Your National Provider Identifier (NPI) and Tax Identification Number (TIN)

• Your business address, state, and office location

• Contact information for any co-providers, if applicable

Service Descriptions, CPT Codes, and Diagnosis Codes

This is the clinical core of your GFE. You'll need to list the services you expect to provide along with their billing codes. Common CPT codes in outpatient therapy include codes for individual psychotherapy at various session lengths, as well as codes for family sessions with patient present and group psychotherapy - your specific codes will depend on the services you provide.

For diagnosis codes, the APA notes that if you haven't completed an initial evaluation yet, it's acceptable to mark the diagnosis field as "TBD" and update the GFE once a working diagnosis is established. If you have a referral with an existing diagnosis, use that.

Cost Estimates and Session Frequency

Clients need a realistic picture of what treatment will cost - not just per session, but over the course of care. Your GFE should include:

• Your per-session fee or fee range

• Expected session frequency (for example, weekly or biweekly)

• Estimated total number of sessions

• A calculated total cost range based on those projections

According to the APA's No Surprises Act FAQ, you can structure a GFE to cover up to a year of services. For new clients, it's also reasonable to provide an initial estimate for the first few sessions and then update it once you have a clearer clinical picture.

Client Rights and Dispute Process

Every GFE must inform clients of their rights. This section should explain:

• That the GFE is an estimate, not a guaranteed price

• That a bill exceeding the estimate by $400 or more triggers the right to dispute

• How to access the patient-provider dispute resolution process

• That the GFE doesn't obligate them to receive care from you specifically

Plain language matters here. The goal is for clients to genuinely understand their rights, not just sign off on them.

How to Customize Your Template by Practice Type

One template won't fit every practice. Your modality, fee structure, and client population all shape what a useful GFE looks like for you.

Individual Therapy vs. Couples and Family Sessions

For individual therapy, your template is relatively simple - one provider, one client, one set of CPT codes. For couples or family sessions, you'll typically bill under a different CPT code and may have a higher session rate. Keeping separate versions - or clearly labeled sections - for each modality saves time at intake and reduces the chance of errors.

Sliding Scale and Self-Pay Fee Structures

If you use a sliding scale, your GFE should reflect the client's actual agreed-upon rate, not your full fee. Document the rate you've agreed to. Avoid using a range so wide it becomes meaningless - the more specific your estimate, the better it serves its purpose and the less likely you are to trigger the $400 dispute threshold.

Group Therapy Considerations

Group therapy GFEs follow the same basic structure, but typically involve a different CPT code and a lower per-session rate. If the group runs for a fixed number of weeks, that makes your total cost estimate easier to calculate. Note the group format and expected frequency clearly so clients understand what they're agreeing to.

Common Compliance Mistakes to Avoid

Most GFE compliance problems aren't intentional - they come from templates that were never fully reviewed or intake processes that move too fast.

Missing Required Template Components

The most frequent issue is an incomplete template. CMS-mandated elements include the client's name and date of birth, a clear service description, expected CPT and diagnosis codes, estimated charges, provider NPI and TIN, and the required dispute rights language. If any of these are missing, your GFE doesn't meet federal requirements.

Failing to Update or Redeliver the Estimate

A GFE isn't a one-time document. If your fees change, the treatment plan shifts significantly, or the projected number of sessions increases substantially, you need to provide an updated estimate. The APA recommends developing a tracking system so your actual billing doesn't quietly outpace your most recent GFE.

Not Documenting GFE Delivery in the Client Record

Per APA guidance, GFEs are considered part of the client's medical record and must be maintained accordingly - for the longer of your state's record-keeping requirements or six years, whichever is greater. Document the delivery date and method in the client's file. If a dispute ever comes up, that documentation is your protection.

Simplify Your Documentation with Berries AI

Getting the GFE right at intake is just the beginning. Once sessions start, you still have progress notes, treatment plans, and session summaries to stay on top of. Berries AI can help streamline your documentation workflow - including generating session notes that align with the CPT codes and diagnosis information already captured in your Good Faith Estimate. Start your free 20-session trial at heyberries.com.

Conclusion

A well-designed Good Faith Estimate template isn't just a compliance checkbox - it sets clear expectations, protects your practice, and strengthens the therapeutic relationship from day one. Take some time to review your current intake documents and make sure your GFE covers every required component. The few minutes it takes to get this right at the start of care pays off every time.

This article is for educational purposes and professional development only. It does not constitute clinical supervision or replace professional judgment in therapeutic practice.

Sources

1. American Academy of Marriage and Family Therapists. (n.d.). No Surprises Act. https://www.aamft.org/AAMFT/enhance_knowledge/No_Surprises_Act.aspx

2. American Psychiatric Association. (2022). No Surprises Act Implementation. https://www.psychiatry.org/psychiatrists/practice/practice-management/no-surprises-act-implementation

3. American Psychological Association. (2022, January 14). FAQs on the No Surprises Act and good faith estimates. https://www.apaservices.org/practice/legal/managed/faqs-no-surprise-act

4. American Psychological Association. (2022, February 23). Understanding the No Surprises Act: How to provide estimates for your services. https://www.apaservices.org/practice/legal/managed/no-surprises-act

5. Centers for Medicare & Medicaid Services. (n.d.). No Surprises Act. https://www.cms.gov/nosurprises

6. California Association of Marriage and Family Therapists. (2021, December). The No Surprises Act: What MFTs Need to Know. https://www.camft.org/Membership/About-Us/E-Newsletters/December-2021-E-News/No-Surprises-Act