Effective January 1, 2022, laws regulating client care have been updated to include the “No Surprises” act, which requires a wide variety of providers to give current and potential future clients a “Good Faith Estimate” (GFE) on the cost of treatment. Per the law, a provider must furnish a self-pay patient with the notice and GFE prior to all scheduled services, or by request if the patient is shopping for care (and not yet at the point of scheduling). This includes, but is not limited to, office visits, therapy, diagnostic tests, infusions, and surgeries.

Who qualifies as a self-pay patient?

A provider’s duty to provide notice and a GFE applies to a self-pay patient, i.e., an individual who (1) does not have insurance benefits for an item or service under a group health plan, group or individual health insurance coverage offered by a health insurance issuer, federal healthcare program, or a health benefits plan; or (2) chooses not to use his or her coverage benefit for the item or service.

In many ways, this regulation protects patients from discovering, after they receive care, that they owe a massive medical bill for un-covered services. This makes sense from a medical point of view – we are all aware of the struggles a patient can go through after discovering their insurance does not cover some services or providers. For example, if an out-of-network provider gives post-surgical care at an in-network hospital, the patient could end up with a big out-of-pocket expense that comes as a complete surprise.

However, therapy is a different form of service where it is often difficult to provide an estimate of how long it may take to process trauma, address anxiety, or minimize depression. There are a number of variables that make it nearly impossible to quantify what will be needed. And there is no way to give a “good faith estimate” on whether or not a client will want to return for a follow-up. In an effort to quell confusion related to cost, before the first session of each self-pay client, a Good Faith Estimate form will be provided, with details of costs for each service type. Feel free to ask questions at