Guide

Good Faith Estimates for a Weekly Service: The Recurring-Care Rule

Summary

Yes. The No Surprises Act requires a good faith estimate for every uninsured or self-pay client, and therapy that repeats weekly is handled as recurring services: one estimate can cover a course of care if it states the frequency, the number of sessions, and the duration, capped at twelve months. Re-issue it when the plan changes and renew it before the year runs out.

By Gale Editorial · Updated 2026-07-26. Every figure cited to a dated source. How we write.

Does a good faith estimate apply to weekly therapy?

Yes. The federal No Surprises Act requires a written good faith estimate for anyone who is uninsured or who chooses not to bill their insurance, and a course of weekly therapy is estimated as recurring services rather than one visit at a time 1Ref 1Centers for Medicare & Medicaid Services (2026).No Surprise Billing.The No Surprises Act good-faith-estimate requirement for uninsured and self-pay clients, the $400 patient-provider dispute-resolution threshold, and the still-unimplemented insured-estimate provisions.. A single estimate covers the expected arc of care, and you refresh it as the plan changes.

The good faith estimate is the self-pay counterpart to the surprise-billing protections the No Surprises Act built for insured emergency and facility care. For a solo practice, it lands at intake: the same conversation where you set the fee is where the estimate belongs. Treat it as the nsa for office practice, not a hospital formality, because an outpatient therapist who sees self-pay clients is squarely inside the rule 2Ref 2Office of the Federal Register (2026).45 CFR Part 149 — Surprise Billing and Transparency Requirements.The regulatory content, the twelve-month recurring-services scope cap, and the delivery-timing deadlines for good faith estimates..

What a recurring-services estimate must include

A recurring-services estimate lists the item or service, the expected frequency, and the total number of sessions, so one document can cover an entire course of care 2Ref 2Office of the Federal Register (2026).45 CFR Part 149 — Surprise Billing and Transparency Requirements.The regulatory content, the twelve-month recurring-services scope cap, and the delivery-timing deadlines for good faith estimates.. The regulation caps that scope at twelve months; if care continues past a year, you issue a fresh estimate for the next stretch 2Ref 2Office of the Federal Register (2026).45 CFR Part 149 — Surprise Billing and Transparency Requirements.The regulatory content, the twelve-month recurring-services scope cap, and the delivery-timing deadlines for good faith estimates.. It also carries your name, practice details, taxpayer and provider identifiers, the diagnosis code, and the service code with its expected charge.

That service code is usually a psychotherapy CPT code — the 90832, 90834, or 90837 timed-session family, plus 90791 for the intake evaluation 3Ref 3APA Services, Inc. (2025).Psychotherapy Codes for Psychologists.The psychotherapy CPT codes (90791 evaluation; 90832/90834/90837 timed individual therapy) itemized on a therapy good faith estimate and reset by a change in session length or frequency.. The twelve-month cap is the detail solo billers miss: an open-ended "ongoing weekly therapy" estimate is not compliant, but "one 90837 session weekly for up to twelve months" is. Handling therapy as recurring services and re-issuing annually is the discipline the gfe at the front desk depends on.

When the estimate is due

The delivery deadline runs from when care is scheduled or requested. When a service is scheduled at least three business days ahead, the estimate is due within one business day; scheduled at least ten business days ahead, within three business days; and when a client simply asks for an estimate, within three business days of the request 2Ref 2Office of the Federal Register (2026).45 CFR Part 149 — Surprise Billing and Transparency Requirements.The regulatory content, the twelve-month recurring-services scope cap, and the delivery-timing deadlines for good faith estimates.. These are the gfe triggers, and the clock is short.

Trigger	Estimate due
Service scheduled at least 3 business days out	Within 1 business day
Service scheduled at least 10 business days out	Within 3 business days
Client requests an estimate (no booking)	Within 3 business days of the request

For a weekly caseload the practical read is simple: build the estimate into intake so it is always delivered before the first session, and keep the request-triggered version ready, because a prospective client is entitled to one before they ever book 1Ref 1Centers for Medicare & Medicaid Services (2026).No Surprise Billing.The No Surprises Act good-faith-estimate requirement for uninsured and self-pay clients, the $400 patient-provider dispute-resolution threshold, and the still-unimplemented insured-estimate provisions.. Deliver it in a way the client can save — paper or a portal document they keep.

The $400 line and why accuracy matters

Accuracy has a defined consequence. When the final bill exceeds the good faith estimate by at least four hundred dollars, the client can take the difference to the patient-provider dispute resolution process, and a certified entity decides what is owed 1Ref 1Centers for Medicare & Medicaid Services (2026).No Surprise Billing.The No Surprises Act good-faith-estimate requirement for uninsured and self-pay clients, the $400 patient-provider dispute-resolution threshold, and the still-unimplemented insured-estimate provisions.. That gap is the $400 tolerance, and it is measured against the estimate you handed over, so a lowball number to win the booking can cost you at the dispute desk.

Estimate honestly and the exposure is small: price the session you actually bill, note that occasional add-ons such as a longer crisis session or a no-show fee are not included, and update the estimate when your fee or the frequency changes 2Ref 2Office of the Federal Register (2026).45 CFR Part 149 — Surprise Billing and Transparency Requirements.The regulatory content, the twelve-month recurring-services scope cap, and the delivery-timing deadlines for good faith estimates.. The estimate is given in good faith, not as a binding quote — but a large, unexplained overage is exactly what triggers a dispute.

Insured clients and the still-delayed insured estimate

If a client is using insurance, the good faith estimate requirement works differently, and much of it is still not in force. The No Surprises Act also envisioned an estimate for insured patients that would flow through the plan into an advanced explanation of benefits, but federal regulators have not implemented that piece and continue to exercise enforcement discretion 1Ref 1Centers for Medicare & Medicaid Services (2026).No Surprise Billing.The No Surprises Act good-faith-estimate requirement for uninsured and self-pay clients, the $400 patient-provider dispute-resolution threshold, and the still-unimplemented insured-estimate provisions.. So the insured gfe is, for now, largely aspirational.

The rule you must follow today is the self-pay one: any client not running the visit through insurance — including an insured client who chooses to see you privately — gets a good faith estimate 1Ref 1Centers for Medicare & Medicaid Services (2026).No Surprise Billing.The No Surprises Act good-faith-estimate requirement for uninsured and self-pay clients, the $400 patient-provider dispute-resolution threshold, and the still-unimplemented insured-estimate provisions.. That includes clients on a plan you are out of network with who decide to pay you directly. When in doubt, ask whether the visit is going through insurance; if not, the estimate applies.

A weekly-caseload workflow

Fold the estimate into three fixed moments and it stops being a burden. First, at intake for every self-pay client, generate a recurring-services estimate — one line, your session code, weekly frequency, up to twelve months 2Ref 2Office of the Federal Register (2026).45 CFR Part 149 — Surprise Billing and Transparency Requirements.The regulatory content, the twelve-month recurring-services scope cap, and the delivery-timing deadlines for good faith estimates.. Second, calendar an annual re-issue before each estimate's twelve-month scope runs out. Third, re-issue on change: a fee increase, a move from weekly to twice-weekly therapy, or a switch to a longer session all reset the number 3Ref 3APA Services, Inc. (2025).Psychotherapy Codes for Psychologists.The psychotherapy CPT codes (90791 evaluation; 90832/90834/90837 timed individual therapy) itemized on a therapy good faith estimate and reset by a change in session length or frequency..

Keep a copy in the client's record with proof of delivery; the estimate is part of your No Surprises Act compliance, and an auditor or a disputing client will ask for it 2Ref 2Office of the Federal Register (2026).45 CFR Part 149 — Surprise Billing and Transparency Requirements.The regulatory content, the twelve-month recurring-services scope cap, and the delivery-timing deadlines for good faith estimates.. A short intake script — "here is what a course of weekly sessions is estimated to cost, and I will update it if anything changes" — satisfies the rule and doubles as an informed-fee conversation.

Common questions

Only if they are not billing that insurance for the visit. A client who chooses to see you privately, or who pays out of pocket because you are out of their network, is treated as self-pay and gets an estimate. If the visit runs through insurance, the separate insured-estimate provisions apply, and those remain largely unenforced for now.

Yes, and that is exactly how recurring care is meant to be handled. A single estimate can list the session code, the weekly frequency, and the total number of visits for up to twelve months. Once the scope reaches twelve months, or the plan of care changes, you issue a new estimate for the next period rather than editing the old one.

A client can dispute the difference through the patient-provider dispute resolution process only when the billed total exceeds the estimate by at least four hundred dollars. Below that line there is no formal dispute path. Estimating honestly and updating the number when your fee or session frequency changes keeps you well clear of the threshold.

No. It is an estimate given in good faith, not a fixed quote, and reasonable variation is expected. What it cannot be is a number pulled far below what you actually charge. Price the session you truly bill, name the extras it excludes, such as a late-cancellation fee, and update it when circumstances change.

It depends on the trigger. For care scheduled at least three business days out, the estimate is due within one business day; for care booked at least ten business days out, within three business days. When someone simply requests an estimate without booking, you have three business days from the request.

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References

1.Centers for Medicare & Medicaid Services (2026). No Surprise Billing. Centers for Medicare & Medicaid Services (CMS). link ✓The No Surprises Act good-faith-estimate requirement for uninsured and self-pay clients, the $400 patient-provider dispute-resolution threshold, and the still-unimplemented insured-estimate provisions.
2.Office of the Federal Register (2026). 45 CFR Part 149 — Surprise Billing and Transparency Requirements. eCFR. link ✓The regulatory content, the twelve-month recurring-services scope cap, and the delivery-timing deadlines for good faith estimates.
3.APA Services, Inc. (2025). Psychotherapy Codes for Psychologists. APA Services, Inc.. link ✓The psychotherapy CPT codes (90791 evaluation; 90832/90834/90837 timed individual therapy) itemized on a therapy good faith estimate and reset by a change in session length or frequency.

https://www.gale.care/for-providers/par-gfe-recurring-therapy · 3 sources. Competitor details are cited to dated public sources and maintained as they change; figures are estimates, not commitments. Synthetic demonstration.

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