Your Right to a Good Faith Estimate

The No Surprises Act took effect on January 1, 2022. Most of the coverage it gets concerns surprise bills from out-of-network emergency care and hospital-based providers, but one part of it applies directly to outpatient mental health: the Good Faith Estimate requirement.

The rule is straightforward. If you do not have insurance, or you have insurance but choose not to use it for a particular service, the provider must give you a written estimate of the expected charges before you receive care. The estimate has to be in writing, has to be given within a specific timeframe, and has to include enough detail that you can compare it against what you are billed later.

This applies to therapy the same way it applies to any other outpatient service. It is your right, not a courtesy, and you do not have to ask for it in any particular way.

When you receive yours

If you schedule at least three business days in advance, we provide your Good Faith Estimate no later than one business day after scheduling. If you schedule at least ten business days in advance, we provide it no later than three business days after scheduling. You can also request an estimate before you schedule anything at all, and we will provide it within three business days of the request.

If your expected course of care changes in a way that changes the estimate materially, you receive an updated one.

What is in the estimate

A Good Faith Estimate for therapy includes:

• The expected service, described plainly and with the diagnosis and service codes that will be billed.
• The expected cost per session.
• The expected number or range of sessions over the estimate period, based on what we know at the time.
• The total expected charges for that period.
• Our practice details and the clinician who will be providing the care.

For therapy, the number of sessions is the part that carries genuine uncertainty. Nobody can tell you at intake exactly how long the work will take, and any provider who quotes a precise number is guessing. What we can do is give you a realistic range based on what you are working on, revisit it as we go, and issue an updated estimate if the picture changes.

What the estimate is not

A Good Faith Estimate is not a bill, and it is not a contract. It does not lock you into a number of sessions, and it does not obligate you to continue. You can stop at any point, and you are only charged for the sessions you attend.

It is also not a guarantee. The estimate reflects what we reasonably expect at the time we write it. If you need more sessions than expected, or fewer, the actual charges will differ. That is expected and is not a violation of anything.

Your right to dispute a bill

If you receive a bill that is at least 400 dollars more than your Good Faith Estimate for the same period of care, you have the right to dispute it through the federal patient-provider dispute resolution process.

To start a dispute you must file within 120 calendar days of the date on the bill. There is a small administrative fee to initiate the process, and the fee may be waived if you meet certain income criteria. During the dispute, the disputed amount does not have to be paid, and the provider cannot move the account to collections or charge late fees on it while the dispute is pending.

The process is handled by the U.S. Department of Health and Human Services rather than by us. You can find the current forms, the fee amount, and the filing instructions at cms.gov/nosurprises, or by calling 1-800-985-3059.

We would much rather you call us first. Most billing gaps come from a change in the plan of care that never made it into an updated estimate, and that is usually resolved in one conversation. But the dispute process exists whether or not we resolve it, and you should know it is there.

If you are using insurance

The Good Faith Estimate requirement applies to people who are uninsured or who are choosing not to use their insurance. If you are using in-network benefits, your cost is set by your plan rather than by our fee schedule, so a Good Faith Estimate is not the right tool. What you want instead is a benefits check: your copay, your coinsurance, whether your deductible applies to outpatient mental health, and whether prior authorization is required.

We check those before your first session, and the full explanation of how to verify them yourself is on rates and insurance.

Keeping your copy

Keep the estimate you receive. If a billing question comes up months later, the estimate is the document that establishes what was expected at the outset, and it is what the dispute process compares the bill against. We keep a copy in your record as well and can send you another one at any time.