Good Faith Estimate for Therapists: What Your Website Must Display Under the No Surprises Act

When the No Surprises Act took effect on January 1, 2022, the mental health community focused heavily on the intake paperwork side: creating a Good Faith Estimate form, explaining it to new clients, documenting it in the file. That workflow exists now in most practices, in varying degrees of completeness.

What gets far less attention — and where a meaningful percentage of private practice therapists are still non-compliant — is the website display requirement.

The No Surprises Act doesn't just require that you hand clients a GFE at the right time. It requires that you make a written notice of their GFE rights available through certain channels, including your website. A client who finds your practice online — which is how most clients find practices today — needs to be able to see that notice before they ever contact you.

This post covers exactly what that notice must say, where it should appear on your site, how the broader GFE process works, and the most common mistakes that put practices at compliance risk. If you've handled the intake paperwork side but haven't thought about your website, this is the piece you need.

The No Surprises Act (part of the Consolidated Appropriations Act of 2021, effective January 1, 2022) creates federal protections against unexpected medical bills. For therapists in private practice, the relevant section is the Good Faith Estimate (GFE) requirement for uninsured and self-pay patients.

The requirement applies to you if any of the following is true:

• You see any clients who are uninsured
• You see any clients who have insurance but are choosing not to use it for therapy (self-pay)
• You accept any out-of-pocket payments, including sliding scale fees
• You provide superbills for clients to submit to their insurance themselves

If you exclusively see clients who use insurance and submit claims to their insurer on their behalf, the GFE requirements are more limited. But for the majority of private practice therapists — especially those who are out-of-network or private pay — the full requirements apply.

The GFE requirement has three distinct pieces that work together:

Requirement	What It Means	When It Applies
Notice of Rights	Inform self-pay and uninsured patients of their right to request a GFE	Website, office, and intake materials (ongoing)
Good Faith Estimate	Provide a written cost estimate before services begin or upon request	Triggered by scheduling or a patient request
Dispute Resolution	Inform patients of their right to dispute bills that exceed the GFE by $400+	Must be included in the GFE document itself

Most compliance guidance focuses on the GFE document itself — the actual cost estimate you provide. The Notice of Rights requirement is equally mandatory but gets far less coverage. It's the piece your website is responsible for.

Federal regulations (45 CFR § 149.610) require healthcare providers — including mental health providers — to notify uninsured and self-pay patients of their right to receive a Good Faith Estimate. This notice must be provided in writing and made available in ways that are accessible to patients, which the regulations explicitly include as your practice website.

The required notice must:

• Be written in plain language (not legalese)
• Inform patients that they can request a GFE before scheduling or at any time
• Be accessible — not buried in a PDF or hidden behind a login
• Appear in formats understandable by the patients you serve

HHS has published a model notice that satisfies the requirement if used as written. Using this exact language (or a substantively equivalent version) protects you from being found non-compliant on the notice requirement:

Right to Receive a Good Faith Estimate of Expected Charges

You have the right to receive a "Good Faith Estimate" explaining how much your medical care will cost.

Under the law, health care providers need to give patients who don't have insurance or who are not using insurance an estimate of the bill for medical items and services.

• You have the right to receive a Good Faith Estimate for the total expected cost of any non-emergency items or services. This includes related costs like medical tests, prescription drugs, equipment, and hospital fees.
• Make sure your health care provider gives you a Good Faith Estimate in writing at least 1 business day before your medical service or item. You can also ask your health care provider, and any other provider you choose, for a Good Faith Estimate before you schedule a service.
• If you receive a bill that is at least $400 more than your Good Faith Estimate, you can dispute the bill.
• Make sure to save a copy or picture of your Good Faith Estimate.

For questions or more information about your right to a Good Faith Estimate, visit www.cms.gov/nosurprises.

This is the language HHS developed. Copy it verbatim — there is no SEO-friendly rewrite you should be doing with required regulatory language.

The regulations say the notice must be "prominently displayed" in accessible locations. They don't specify an exact URL or page type, which gives you flexibility — but they do signal that it can't be hidden where patients won't find it.

Here are the placement options that satisfy "prominently displayed," ranked by best practice:

Placement	Compliance Strength	Notes
Dedicated /fees or /billing page	Strong	Most professional; pairs naturally with your rate information; easy to link from navigation
Contact or intake page	Strong	Good placement because prospective clients reach it when initiating contact; pairs with scheduling context
FAQ page (under a "Fees & Billing" section)	Strong	Natural location; easy for patients to find when they have cost questions
Footer of every page	Acceptable	Ensures visibility site-wide but footer placement may be considered "not prominent" if very small; combine with another location
Homepage only (buried below fold)	Borderline	Technically accessible but likely insufficient if not easily discoverable
PDF linked from a small text link	Insufficient	Not accessible by web standards; violates spirit of the requirement
Only in intake paperwork (not on website)	Non-compliant	Intake papers satisfy a different part of the requirement; the website notice is separate and required

The recommended implementation: create a standalone /fees page that lists your session rates, sliding scale policy (if applicable), accepted payment methods, and the full GFE notice block. Link to it from your main navigation or a visible footer link. This gives prospective clients the cost information they're looking for anyway, while satisfying the display requirement in a discoverable, compliant location.

If your site doesn't have a fees page yet — a page that covers what you charge and how payment works — the GFE requirement is a good forcing function to build one. It's also one of the five pages every therapist website needs.

The website notice establishes that you'll provide a GFE. The GFE itself is a separate document — a written cost estimate you provide to self-pay and uninsured clients either when they schedule or when they request one. These are two distinct compliance obligations; satisfying one doesn't satisfy the other.

When you must provide the GFE:

Scheduling Timing	GFE Must Be Provided Within
Appointment scheduled within 3 business days	1 business day of scheduling
Appointment scheduled 4–9 business days out	3 business days of scheduling
Appointment scheduled 10+ business days out	10 business days of scheduling
Patient requests an estimate (no appointment scheduled)	3 business days of the request

What the GFE document must include:

• Your name, NPI (National Provider Identifier), and practice address
• The patient's name and date of birth
• Description of the services (CPT codes for psychotherapy; for example, 90837 for a standard 53–60 minute session)
• ICD-10 diagnosis code(s), if known at the time of the estimate
• Expected charges for each service
• Anticipated service dates or date range
• A total expected cost for the period of care covered by the estimate
• A statement that the estimate is not a contract and actual charges may vary
• The dispute resolution notice (if the actual bill is $400+ more than the GFE, the patient can dispute)

For ongoing therapy, the GFE typically covers a specific period — commonly 12 weeks or a calendar quarter — with an estimated number of sessions and a per-session rate. You don't need to predict every future session; you need to give a reasonable estimate for the near-term course of care.

A practical note on diagnosis codes: For initial consultations before a diagnostic picture has formed, you can use the "anticipated" diagnosis category or use a general V-code (like Z03.89, encounter for observation for suspected condition). Don't fabricate a specific diagnosis just to complete the GFE. If you don't yet have a diagnosis, document that and use the best available code.

This is the most common question, and the answer is nuanced.

If you are in-network and bill insurance for a client: The GFE requirement doesn't apply for that client's insurance-covered services. Insurance-covered services have their own cost-sharing transparency mechanisms (EOBs, advance cost estimates from insurers). However, if that same client has a secondary service you charge separately (like a letter fee, a missed appointment charge, or an additional service not covered by their plan), the GFE requirements may apply to those out-of-pocket components.

If you are out-of-network: The GFE requirements apply fully. Even if a client expects their insurance to reimburse a portion, if you are not submitting claims on their behalf — if they're paying you out of pocket and submitting the superbill themselves — they are functionally a self-pay patient for these purposes.

If you offer sliding scale or reduced fees: The GFE requirements apply. A sliding scale rate is a self-pay arrangement.

If you have a mixed practice (some insurance, some self-pay): The GFE requirements apply to your self-pay clients. Your website notice should be visible to all visitors, since you don't know when a prospective client loads your site whether they'll be using insurance or not.

The practical upshot: if you see any self-pay clients at all, your website needs the notice. The cost and effort to add it is minimal; the cost of non-compliance is not.

Based on the pattern of questions in therapist communities and the compliance guidance published by mental health associations, these are the mistakes most often found in private practice websites:

1. Having the GFE form in intake paperwork but no notice on the website.
The intake paperwork satisfies the requirement to provide a GFE to a scheduled client. The website notice is about informing prospective clients who haven't yet scheduled. These are different obligations; having one doesn't eliminate the other.

2. Paraphrasing or summarizing the model notice language.
The HHS model notice is carefully worded to satisfy the regulatory requirement. When therapists rewrite it to sound more personal or conversational, they sometimes omit the specific rights language or the cms.gov reference. Use the model language as-is; add context around it if you'd like, but don't replace it.

3. Putting the notice only in a PDF linked from a small text link.
A PDF satisfies accessibility requirements only if it's an accessible PDF (tagged, screen-reader-readable). A link to an inaccessible PDF from an obscure footer location doesn't satisfy "prominently displayed." The notice should be HTML text on a reachable, indexable page.

4. Confusing the GFE with "fees and payment" copy.
"Sessions are $175/50 minutes. I accept FSA/HSA cards and Zelle" is fees-and-payment copy. It is not a Good Faith Estimate notice. Fees-and-payment copy is valuable and should live on your site — but it doesn't satisfy the regulatory requirement. You need both.

5. Not updating the GFE notice after the practice changes rates.
The website notice is a standing notice of rights, not a price list — so it doesn't need to be updated when rates change. But if you reference specific rates anywhere near the notice, keep them current so patients aren't misled about what to expect before requesting a formal GFE.

6. Omitting the dispute resolution information from the GFE document.
The $400 dispute right must be in the GFE document. It can't just be in the website notice. If your GFE template doesn't include dispute information, revise the template.

Here's a full picture of what a compliant GFE process looks like for a typical private-pay therapy practice, from website through intake:

Step 1: Website notice (ongoing)
Your /fees or /billing page — or your contact/FAQ page — displays the full HHS model notice text. It's visible HTML (not a PDF, not image text), reachable from your navigation, and doesn't require login or form submission to view.

Step 2: Initial contact
A prospective client finds your notice on your website, sees their rights, and contacts you to schedule. (Or they contact you first and you send them to the notice — either sequence is fine.)

Step 3: GFE delivery
When the client schedules their first session, you provide the GFE document via email or your client portal. If they scheduled 4+ business days out, you have up to 3 business days to send it. If they scheduled quickly, you have 1 business day. The GFE covers their expected sessions and costs for the near-term course of care (commonly 12 weeks).

Step 4: Client acknowledgment
Include an acknowledgment in your intake paperwork that the client received and reviewed the GFE. Keep a copy in the file.

Step 5: Renewal
If care extends beyond the GFE period or the fee structure changes, provide an updated GFE. There's no hard deadline for how often to renew, but HHS guidance suggests renewing annually for ongoing clients or whenever a material change to expected charges occurs.

The full process is not burdensome — for most practices, it's a one-time setup of the website notice and GFE template, plus a brief routine at intake. The website piece is the one step that gets skipped most often and the one that reaches prospective clients before you have any direct contact with them.

The No Surprises Act enforcement for the GFE provisions is handled by HHS's Centers for Medicare & Medicaid Services (CMS). Penalties for non-compliance can reach $100 per violation under initial interpretations, with each patient who should have received a GFE or notice potentially constituting a separate violation.

As of 2026, enforcement against individual private practice therapists has been limited — CMS has focused initial enforcement activity on hospitals, health systems, and providers generating high complaint volumes. However, several factors make individual practice compliance worth maintaining:

• Complaint-driven investigation. CMS enforcement is largely complaint-driven. A client who feels blindsided by a bill and discovers you don't have a GFE process has a clear path to filing a complaint. The website notice is your most visible signal of good-faith compliance.
• State-level amplification. Several states have enacted supplemental No Surprises Act requirements that exceed the federal floor. If you practice in California, New York, Illinois, or several other states, check your state requirements — they may impose additional obligations or shorter response windows.
• Licensing board risk. A patient complaint about missing cost estimates can reach your licensing board as an ethics violation (failure to be transparent about fees), not just a CMS complaint. Most ethics codes require fee transparency; the GFE framework codifies that obligation in federal law.

The good news: the compliance barrier is low. Adding the notice to your website, creating a standard GFE template, and building the delivery into your intake workflow takes a few hours of setup. Once done, it's a standing compliance posture that doesn't require ongoing effort.

Run through this checklist before your next intake:

• ☐ Website notice present? Search your site for "Good Faith Estimate" — does the HHS model notice language appear on a publicly accessible page?
• ☐ Notice is HTML text, not PDF-only? Is it readable without downloading anything?
• ☐ Notice is prominently placed? Is it on your fees/billing page, contact page, or FAQ — not buried in a footer or hidden in a sub-menu?
• ☐ GFE template exists? Do you have a reusable document that includes your NPI, CPT codes, expected charges, period of care, and dispute information?
• ☐ GFE delivery workflow? Is there a step in your intake process that triggers sending the GFE within the required window after scheduling?
• ☐ Client acknowledgment? Is there an acknowledgment in your intake forms that the client received the GFE?
• ☐ State supplements reviewed? Have you confirmed whether your state has additional GFE requirements beyond the federal baseline?

If you checked all seven, your practice is in solid shape on the GFE requirements. If you found gaps, the website notice is typically the fastest to fix — it can be added to your site today with the model language above.

WebsiteTherapy sites include a compliance-ready fees page template during onboarding, pre-loaded with the HHS model notice in the correct placement. Like the platform's approach to HIPAA compliance and ADA requirements, the goal is a therapy website that handles the regulatory layer automatically — so your mental bandwidth stays on clinical work, not compliance audits.