Good Faith Estimates for New Clients in 2027: What Therapists Need to Get Right in January

January is when a lot of people finally book that first therapy appointment. New year, new plan, sometimes a new insurance plan with a deductible they'd rather not touch. A good share of those people pay out of pocket.

Every one of them is owed a Good Faith Estimate.

Most therapists know the term. Fewer feel sure they're doing it right. And January is the month when the gaps show up, because that's when new clients pile in, fees change and last year's estimates quietly go out of date.

This guide covers who needs a Good Faith Estimate, when it's due, what has to be on it and the January mistakes we see most. If you'd rather skip ahead, our free Good Faith Estimate generator will build one for you.

This is general information, not legal advice. For anything specific to your practice or your state, check with a healthcare attorney or compliance advisor.

What a Good Faith Estimate is

The No Surprises Act, which took effect on January 1, 2022, says that clients who are uninsured or choose not to use their insurance have a right to know what their care will cost before it starts. The Good Faith Estimate, or GFE, is the written document that tells them.

It applies to licensed mental health providers: therapists, counselors, psychologists, social workers and marriage and family therapists. If you see self-pay clients, it applies to you.

Who needs one

You owe a GFE to two groups of people:

• Uninsured clients. Anyone without health coverage for the service.
• Self-pay clients. People who have insurance but don't plan to use it for therapy with you. That includes a lot of private-pay practices and clients who see you out of network and choose not to have claims sent to their plan.

You also owe one to anyone who asks about cost, even if they haven't booked. If someone emails "how much do you charge, and how many sessions do people usually need?", that counts as a request.

The out-of-network and superbill situation is where practices disagree the most. If you hand clients superbills to submit themselves, talk to your compliance advisor about whether you're treating them as self-pay. Many practices give a GFE anyway, because it costs nothing and protects everyone.

When it's due

The deadlines depend on how far out the first appointment is:

• Booked 3 or more business days out: send the GFE within 1 business day of scheduling.
• Booked 10 or more business days out: send it within 3 business days of scheduling.
• Someone asks for one without booking: send it within 3 business days of the request.

It has to be in writing. Email or a client portal is fine, as long as the client can keep a copy (and print it if they want to).

What a Good Faith Estimate has to include

This is where most homemade templates fall short. A complete GFE includes:

• The client's name and date of birth
• A description of the service, for example weekly 53-minute individual psychotherapy
• An itemized list of expected services with the expected charge for each
• Service codes (CPT codes like 90791 or 90837) and diagnosis codes where you have them
• Your name, NPI, tax ID and the location where services happen
• If another provider will be involved, their expected charges too
• A note that the estimate isn't a contract and the client doesn't have to receive the services
• A note that if the bill comes in at least $400 more than the estimate, the client can dispute it, with information on how to start that process

For ongoing therapy, you can't know exactly how many sessions someone will need. That's fine. Give a reasonable estimate, for example 12 weekly sessions, and say clearly that it's an estimate. A GFE for recurring care can cover up to 12 months. If care continues past that, you issue a new one.

The January mistakes we see most

Raising your fee without updating the GFE. If you're increasing your rate on January 1, every self-pay client with a GFE at the old rate needs a new one. Otherwise the gap between estimate and bill grows every session, and on weekly therapy it can pass $400 faster than you'd think.

Letting last year's GFEs expire. If you issued 12-month estimates last January, a lot of them run out right about now. Put a reminder on your calendar to reissue them.

Treating it as a one-time form. Changed the session length? Added a family session? Moved a client from biweekly to weekly? The estimate should change with the plan.

Forgetting the notice on your website. You also have to tell people they have a right to a GFE. That notice should be on your website, in your office and anywhere you schedule. A short section on your fees page or contact page usually does it. CMS publishes a model notice on its No Surprises page (opens in a new tab).

Not keeping copies. Keep every GFE you issue with the client's record. If a client ever disputes a bill, the estimate is the document everything is measured against.

What happens if a client disputes a bill

If a self-pay client gets billed at least $400 more than their estimate, they can start a patient-provider dispute resolution process through CMS. They generally have 120 days from the first bill to do it. An independent reviewer looks at the estimate and the bill and decides what the client owes.

For most therapists this never happens, because therapy fees are predictable. When it does, it's usually because of one of the January mistakes above: a fee increase or a change in session frequency that never made it onto a new estimate.

What about clients who use their insurance?

For now, the GFE rules only apply to uninsured and self-pay clients. The law also describes a version for insured clients, where providers send an estimate to the insurer and the insurer sends the client an "Advanced Explanation of Benefits." But federal agencies have held off on enforcing that part while they work out how providers and insurers will exchange the data. Keep an eye on it, but you don't need to act on it in January.

If you take Medicare clients, our Medicare 2027 post covers what else changes in January.

Make it easy on yourself

GFEs aren't hard. They're just one more piece of paperwork in a week that's already full. That's why we built a free Good Faith Estimate generator for therapists. Fill in your practice details, add the client and the planned services, and you get a clean estimate to send.

If you want help with the rest of your site, like adding the GFE notice to your fees page or making your contact and booking flow ready for January, book a free 30-minute call (opens in a new tab). We'll look at it with you.

And if a client asks for an estimate tomorrow morning, you know where the generator is.