Good Faith Estimates:
Are You Compliant?
The No Surprises Act has required Good Faith Estimates since January 2022. Most small independent practices still aren't doing it right — and the penalties are real.
What the Law Actually Requires
The No Surprises Act — specifically the Good Faith Estimate provision — went into effect January 1, 2022. It applies to every healthcare provider, including OT, PT, ST, optometry, and ophthalmology practices.
If a patient is uninsured, self-pay, or simply asks for one, you are legally required to provide a written Good Faith Estimate of expected charges before scheduled services. This isn't optional guidance — it's federal law enforced by the HHS Office for Civil Rights.
A compliant GFE must include:
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Written GFE provided before any scheduled service
- ✓
Must include expected charges for the primary item or service
- ✓
Must include charges from all providers and facilities involved in the visit
- ✓
Must be given at least 1 business day before the service for scheduled appointments
- ✓
Must be provided within 3 days of patient request, or 1 day if appointment is within 3 days
- ✓
Must be retained in the patient record for at least 6 years
The Cost of Non-Compliance
Up to $149
per violation
The penalty for failing to provide a Good Faith Estimate when required.
$2,500
dispute threshold
If the final bill exceeds the GFE by more than $400, the patient can initiate a federal arbitration dispute — and you'll likely lose.
6 years
retention required
Every GFE you issue must be retained in the patient record for 6 years.
Who Requires a GFE?
It's not just uninsured patients. The requirement is broader than most practices realize.
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Uninsured patients (no coverage at all)
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Self-pay patients (choosing not to use their insurance)
- ✓
Any patient who requests a GFE — insured or not
What Most Practices Are Doing
We've seen the same four approaches — none of them fully compliant:
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A Word document that gets manually filled out per patient — inconsistent, slow, and hard to audit
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Nothing at all — and hoping no one asks
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A spreadsheet with outdated fee schedules
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A verbal estimate with no written record
How We Fix It
We start with a compliance audit so we know exactly where you stand, then implement the right solution for your practice size and workflow.
GFE Compliance Audit
$300
One-time
We review your current workflow against No Surprises Act requirements and identify exactly where you're exposed. You'll get a plain-English gap report.
GFE Template Package
$500
One-time
Compliant, branded GFE templates for your specialty — pre-filled with your service codes, fee schedule, and required disclosure language. Ready to use immediately.
Custom GFE Tool
Starting at $1,500
One-time build
A lightweight internal web app your front desk uses to generate compliant GFEs in under 2 minutes. Select the patient, the services, and click print. Logs every estimate automatically.
EHR/PM Integration
Scoped per system
After free discovery
If your EHR or practice management system supports it, we integrate GFE generation directly into your scheduling workflow so it triggers automatically.
This Isn't Going Away
HHS enforcement of the Good Faith Estimate requirement has been ramping up. Patient awareness is growing — billing transparency is now expected, not optional. Practices that get their GFE workflow right now will be ahead of the practices scrambling to catch up after the first complaint.
The good news: with the right template or tool, issuing a compliant GFE takes under two minutes per patient. We can get you there.
Start with a Free Compliance Check
During your free practice audit, we'll review your current GFE workflow and tell you exactly where you stand — at no cost.
Get Your Free Practice Audit