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Who needs a GFE

The No Surprises Act, effective January 1, 2022, requires health care providers to give a written Good Faith Estimate of expected charges to individuals who are uninsured, and to insured individuals who tell the provider they don’t plan to submit a claim to their health plan for the service. In private-pay therapy practice, that covers most self-pay clients and any insured client who asks to pay out of pocket instead of billing their plan.

It applies once a client schedules an appointment, or asks for a cost estimate for scheduling one. A general fee-schedule conversation, before anything is booked, doesn’t trigger it.

Delivery timing

The estimate has to reach the client by a specific deadline, measured from the appointment date:

• Appointment scheduled at least 3 business days out: estimate owed no later than 1 business day before.
• Appointment scheduled at least 10 business days out: estimate owed no later than 3 business days before.
• Appointment scheduled fewer than 3 business days out: an estimate isn’t required by this timing rule, though many practices send one anyway.

EstimateHarbor doesn’t track your appointment calendar — it sends the estimate the moment you tell it to. Build sending into your intake process so it goes out with enough runway.

What has to be in it

Every EstimateHarbor PDF includes the elements CMS requires: client name and date of birth, the provider’s name, NPI, and TIN, the location where care will be furnished, an itemized list of expected services with CPT/HCPCS codes and per-service charges, the total expected cost, a diagnosis code if one has already been assigned, and the standard disclosures — that it’s not a bill, not a contract, not a guarantee against unforeseen charges, that it’s valid for 12 months, and the dispute-resolution notice below.

The dispute process

If a client is later billed at least $400 more than their Good Faith Estimate for the same provider and the same or similar services, they can start the patient-provider dispute resolution process within 120 calendar days of the bill. There’s a filing fee, refunded if the dispute is decided in their favor. Providers who don’t provide a required estimate — or who bill well beyond it without a defensible reason — can face civil penalties of up to $10,000 per violation. Full instructions for clients are at www.cms.gov/nosurprises or 1-800-985-3059.

Recurring care

Weekly therapy doesn’t need a new estimate every visit. When a client’s expected course of care runs 12 months or longer, a single Good Faith Estimate can cover that whole period. EstimateHarbor detects this from the frequency and session count you enter and adds the recurring-services notice automatically. You still need to issue a new estimate at least once every 12 months, and sooner if the frequency or scope of care changes — that’s what the renewal reminder on the Solo and Clinic plans is for.

What we store

EstimateHarbor stores what a Good Faith Estimate requires — client name, date of birth, an optional diagnosis note if you enter one, and the service and cost details — not session notes, treatment plans, or anything else from the clinical record. Client name, date of birth, email, and your practice’s TIN are encrypted at rest. See the data & PHI notice for specifics.