Good Faith Estimate Requirements: Timing, Content, and Disputes

If you don’t have health insurance, or you’re choosing not to use it for a particular service, your provider must give you a written Good Faith Estimate of expected charges before you receive scheduled care. The Good Faith Estimate requirements under the No Surprises Act took effect January 1, 2022, and they cover the primary service plus every related item and provider cost you can reasonably expect. If the final bill from any one provider comes in at least $400 above that provider’s portion of the estimate, you can dispute it.¹

Who Qualifies for an Estimate

Two groups are entitled to a Good Faith Estimate. The first is anyone without health insurance, including people not covered by an employer plan, a marketplace plan, Medicare, or Medicaid. The second is anyone who has insurance but tells the provider they plan to pay out of pocket rather than file a claim. Telling the provider you’re self-pay is enough to trigger the requirement.¹

One boundary matters. The estimate rules apply to scheduled or requested services, not emergency care. Separate No Surprises Act provisions cover surprise billing in emergencies, but they work through a different mechanism.²

Providers also can’t wait to be asked. The rule requires them to inform uninsured and self-pay patients that an estimate is available, through a notice on the provider’s website, visible signage where scheduling happens, and an oral explanation when a patient books a service or asks about cost.³

When the Estimate Has to Reach You

The deadline depends on how far ahead the service is booked, and whether you’ve actually scheduled anything or only asked for a quote:

Service scheduled 10 or more business days out: estimate within three business days of scheduling.
Service scheduled 3 to 9 business days out: estimate within one business day of scheduling.
Service scheduled fewer than 3 business days out: no estimate is required.
Estimate requested without scheduling anything: provider must furnish it within three business days of the request.

The estimate must be in writing, on paper or electronically, based on what you prefer.¹

For recurring care like physical therapy or infusions, a single estimate can cover all planned sessions, but only up to 12 months. Treatment continuing past that window needs a fresh estimate.¹

If anything about the planned care changes after you receive the estimate — different charges, added items, a different frequency, or a change of provider — the provider must issue an updated estimate no later than one business day before the service is furnished.¹

What Has to Be on the Estimate

A Good Faith Estimate is not a one-line quote. The regulation requires each estimate to include:

A plain-language description of the primary service, and the scheduled date if there is one.
An itemized list of every item and service reasonably expected across the full period of care, grouped by each provider or facility involved.
The applicable diagnosis codes, expected service codes, and expected charges for each listed item.
The name, National Provider Identifier, and Tax Identification Number of every provider or facility on the list.
A disclaimer that the figures are an estimate of what’s reasonably expected at the time of issuance, and that actual charges may differ.
A separate disclaimer that the estimate is not a contract and you are not required to obtain services from any listed provider.

The second disclaimer matters. You keep the right to shop around or cancel without penalty, regardless of what the estimate says.¹

How Multi-Provider Care Gets Bundled

Most procedures pull in more than one provider. A surgery might involve a surgeon, an anesthesiologist, a pathology lab, and the facility. Rather than making you chase each estimate down, the rule appoints a single “convening provider” — the one who schedules the primary service or receives your request — to build a unified estimate.

The convening provider has one business day after scheduling or receiving the request to contact every co-provider expected to participate. Each co-provider then has one business day to send its estimated charges back. You should end up with one document listing all expected costs, grouped by provider.¹

This is often where the process breaks. Co-providers miss the turnaround, or the convening provider doesn’t identify every specialist who will be involved. If your estimate looks incomplete, ask about the missing pieces and request a new estimate if the scope of care shifts.

Disputing a Bill That Exceeds the Estimate

If your final bill runs substantially higher than the estimate, you can challenge it through the patient-provider dispute resolution process. “Substantially higher” has a specific meaning here: the billed charges from a particular provider or facility must exceed that same provider’s or facility’s portion of the estimate by at least $400. The comparison happens provider by provider, not on the total bill.⁴

To file, submit an initiation notice to HHS through the federal Independent Dispute Resolution portal within 120 calendar days of receiving the bill. HHS charges an administrative fee to file. The case is assigned to a certified Selected Dispute Resolution entity, an independent third party, which has 30 business days after receiving the necessary information to issue a payment determination.⁴

You and the provider can also settle at any point before the determination is issued. A settlement can be a financial assistance offer, an agreement to accept a lower payment, or your decision to pay the billed amount in full.²

Protections While the Dispute Is Open

Filing does not leave you exposed. While the dispute is pending, the provider must suspend late fees on the unpaid amount, cannot send the disputed bill to collections or threaten to, and must halt collection efforts already underway if the bill had been sent out before you filed.²

An anti-retaliation rule also applies. A provider cannot refuse future treatment, downgrade your care, or otherwise punish you for using the dispute process.²

If a Provider Never Gave You an Estimate

Report the violation to CMS through the No Surprises Help Desk. Complaints can be filed online on the CMS website or by phone at 1-800-985-3059. Include what you have: appointment confirmations, correspondence with the office, and any estimate you eventually received. CMS reviews whether surprise billing rules were followed and can refer the matter to the appropriate federal or state enforcement authority.⁵