Good Faith Estimates under the No Surprises Act

Who this covers

The Good Faith Estimate requirement applies when you are uninsured or when you tell the provider you will not use insurance for the service (self-pay). It applies to most health care providers and facilities, including hospitals, surgery centers, imaging centers, and clinician offices, for items and services they expect to provide. If you are insured and using your plan, the plan side of the comparison is covered in estimating your cost with insurance.

Separate surprise-billing protections in the No Surprises Act also limit out-of-network cost-sharing for emergency care and for certain non-emergency care at in-network facilities. Those protections are about insurance cost-sharing, not cash quotes. This guide focuses on the estimate you can request before a scheduled, shoppable service. For how those emergency protections change the urgent care versus emergency room decision, see Urgent care vs ER: where to go and what it costs.

The regulation behind all of this is 45 CFR 149.610, and its definitions settle two points patients often get wrong. First, the self-pay category is wider than "no insurance": it includes a person who has a group or individual plan but does not seek to have a claim submitted for the item or service. Second, the category is narrower than "anyone paying out of pocket": the opt-out route applies only to group and individual health coverage and federal employee plans. A person who has benefits for the item under a Federal health care program, such as Medicare or Medicaid, is not covered by the self-pay half of the definition, so declining to bill the program does not turn that person into a self-pay patient for the estimate rules. The provider is also told how to find out which group you are in. The rule requires it to ask whether you are enrolled in coverage and, if so, whether you want a claim submitted, and it says the provider must treat any discussion or inquiry about the potential cost of items or services as a request for an estimate. You do not need the words "Good Faith Estimate" for the clock to start. A question about price is enough.

When you get the estimate

• When you schedule a service at least 3 business days in advance, the provider should give the estimate within 1 business day after scheduling.
• When you schedule at least 10 business days in advance, the estimate should be given within 3 business days after scheduling.
• When you ask for an estimate without scheduling, it should be given within 3 business days of the request.

The CMS consumer page states the edge case the list implies: when you schedule care 0 to 2 business days in advance, you are not entitled to an estimate. If you asked for an estimate before scheduling, the rule also requires a new estimate once the service is actually scheduled, on the same 1 or 3 business day timetable, so a price you obtained while shopping is replaced by one tied to a date.

Because the deadlines run in business days, count them that way, leaving out weekends and holidays, and if a booking sits near the 3 or 10 day line, ask the office which timetable it is applying. Write the scheduling date on your own notes the day you book, because every later step in this guide, the update deadline, the dispute eligibility, and the evidence you will need, is measured from dates you can prove.

What the estimate should list

Element	Why it matters
Patient and provider identification	Names, contact information, and the provider tax identification where required
Description and codes	Each item or service with its CPT or other code, so the estimate matches the bill
Expected charges by provider	Each provider's or facility's expected charges grouped under its name; a group that bills separately, such as anesthesia or pathology, may give you its own estimate
Service location	The setting where each item will be furnished
Disclaimers and next steps	That actual charges may differ if the plan changes, and how to dispute

If a line you expect from this provider is missing, ask for a revised estimate that lists it. If a whole layer is missing because another group bills it, such as the professional, anesthesia, or pathology bill for a procedure, ask that group for its own estimate, as the co-provider section below explains.

The full checklist, paragraph by paragraph

The table above is the short version. The regulation itself, at 45 CFR 149.610(c)(1), lists what an estimate issued to an uninsured or self-pay person must include, and it is worth checking a real estimate against the full list once, because the items people overlook are the ones that matter later in a dispute.

1. Your name and date of birth.
2. A description of the primary item or service in clear language, and the scheduled date if there is one.
3. An itemized list of the items or services reasonably expected for that period of care, grouped by each provider or facility.
4. For each listed item, the applicable diagnosis codes, the expected service codes, and the expected charge.
5. The name, National Provider Identifier, and Tax Identification Number of each provider or facility on the estimate, and the state and office or facility location where each expects to furnish its items.
6. A list of items the convening provider expects will need separate scheduling before or after the period of care, under a disclaimer saying separate estimates will be issued for them on scheduling or request.
7. A disclaimer that the provider may recommend other items or services that must be scheduled or requested separately and are not reflected in the estimate.
8. A disclaimer that the estimate is only an estimate and that actual items, services, or charges may differ.
9. A disclaimer of your right to start the patient-provider dispute process if billed charges are substantially in excess of the estimate, with instructions for where to find out how, and a statement that starting it will not adversely affect the quality of your care.
10. A disclaimer that the estimate is not a contract and does not require you to obtain the items or services from any provider or facility named in it.

The regulation numbers these from (i) to (xi), with one paragraph, (vii), marked reserved, which is why the list above has ten items. Two of them do most of the work if a dispute follows. Item 4 is the one that lets you compare an estimate with a bill line by line: the bill will carry service codes, and an estimate with codes can be matched code for code. Item 5 is the one that makes the estimate provider-specific: the dispute test described below is run against the estimate for one named provider or facility, so an estimate that does not identify who stands behind each group of charges is harder to use later. The rule also fixes the form. The estimate must be written, on paper or electronically as you request, and an electronic copy must be one you can both save and print. A provider may talk you through the estimate by phone or in person if you ask, but the written copy still has to follow.

One estimate or several: the co-provider part CMS is not enforcing

On paper, the regulation describes one combined document. The provider who receives your request and would schedule the main service is the convening provider or facility. Within 1 business day of scheduling or a request, it is supposed to contact every co-provider and co-facility reasonably expected to furnish items in conjunction with the main service, such as an anesthesia group or a pathology lab, and the co-providers are supposed to send their information back within 1 business day, for the convening provider to fold into one estimate.

That combined estimate is not what CMS now tells patients to expect, and the reason is an enforcement decision, not the text of the rule. In FAQs dated December 2, 2022, HHS said it was extending enforcement discretion, pending future rulemaking, for estimates that do not include expected charges from co-providers or co-facilities. It gave the reason as the technical work needed for providers to exchange estimate data, and said any future rule would carry a prospective date giving providers a reasonable time to comply. A search of the Federal Register on October 29, 2026 for rules and proposed rules since January 1, 2023 that mention Good Faith Estimates and co-providers returned none. The CMS consumer page, last modified October 5, 2026, describes the practical result in plain words: estimates "only list expected charges for a single provider or facility," and for a surgery it suggests requesting two, one from the surgeon and one from the hospital.

So the working rule for a procedure with several billers is to collect several estimates. Ask the convening provider which other groups are expected to bill for the period of care, and whether their charges are on its estimate. For any group that is not on it, contact that group and ask for its own Good Faith Estimate. The regulation supports the request: if you separately schedule or request an estimate from a provider that would otherwise have been a co-provider, that provider becomes a convening provider for its own items and owes you an estimate on the same deadlines. Keep each estimate with the name of the provider it covers, because each one is the yardstick for that provider's bill and no other.

If the estimate is missing, late, or incomplete: work the dates first

A missing estimate is a billing record problem you can document. It is not a reason to guess a price or to fill the gap with a figure from another facility. CMS guidance says information about the availability of a Good Faith Estimate should be found in three places: on the provider or facility website, in the office or on site where patients schedule care or ask about costs, and from the provider in writing or orally when a patient asks about the cost of an item or service. The same guidance says that information must be available in accessible formats and languages. If you asked about cost and none of that information appeared, write that fact down while the conversation is still fresh.

Use a worksheet with only figures and dates you enter yourself. Record the date you scheduled the service or requested the estimate without scheduling, the date and setting of the service, the date any estimate actually arrived, and the name of the convening provider or facility. Then test what you hold against the timing rules above: scheduled at least 3 business days ahead, an estimate due within 1 business day after scheduling; scheduled at least 10 business days ahead, an estimate due within 3 business days; requested without scheduling, an estimate due within 3 business days of the request. If the dates do not line up, say so in one written sentence to the billing office, naming the scheduling date, the due date under that rule, and the arrival date. Keep a copy of that note with the estimate folder.

Check two completeness points that are easy to miss. First, CMS guidance says the estimate should also list items and services that the convening provider or facility expects will need separate scheduling, before or after the period of care for the main item or service. A separate lab visit or a follow up item that needs its own booking belongs on that list, not as a surprise line later. Second, you can ask for the estimate to be explained orally, in person or by phone, and the written estimate still has to follow. The estimate itself is not a bill and it is not a contract. It shows the items and services reasonably expected for your health care needs, based on information known when it was created, and it does not include unknown or unexpected costs that arise during care. If the estimate still does not arrive, do not invent a substitute figure. Ask in writing once more, keep the request, and then use the CMS No Surprises consumer pages or the No Surprises Help Desk at 1-800-985-3059 for the current contact route and next step.

The CMS consumer page adds the consequence that makes this worth the effort: you need a Good Faith Estimate to dispute a bill, and you cannot dispute without one. If you did not get an estimate you think you were owed, CMS directs you to submit a complaint, and says plainly that a complaint does not relieve you of paying the bill.

Source: Centers for Medicare and Medicaid Services, Learn more about the Good Faith Estimate and the Patient-Provider Dispute Resolution process for people without insurance or who plan to pay for the costs themselves, dated December 21, 2021, checked October 29, 2026; CMS, What is a good faith health insurance estimate?, page last modified October 5, 2026, checked October 29, 2026.

When the estimate must be updated

The first estimate is not the last word if the plan changes before the service date. The convening provider or facility must give you a new Good Faith Estimate when it expects, or is notified of, a change to the scope of the original estimate. Scope means more than the total. It includes the expected charges, the items and services themselves, their frequency, how often they recur, how long they last, and which providers or facilities will furnish them. A change that comes from a co-provider or co-facility, for example anesthesia or pathology added to a procedure, counts in the same way as a change made by the convening provider itself.

The timing is specific. The new estimate must reach you no later than 1 business day before the items or services are scheduled to be furnished. When it is delivered, the provider or facility must also communicate the changes to you, to help you understand what has changed between the initial estimate and the new one. That explanation is part of the protection, not a courtesy extra. Read it line by line: which code was added, removed, or replaced, which billing layer moved, and what charge changed with it. If the explanation names a change but the lines do not show it, ask for that line to be corrected before service.

Recurring care follows the same rule in a longer form. A provider may issue a single estimate for recurring items or services, such as a series of visits over time, instead of a new estimate for every instance. That single estimate must state the expected scope clearly, including the timeframes, the frequency, and the total number of recurring items or services. Its scope must not exceed 12 months. If more recurrences are expected beyond 12 months, a new estimate is required. Keep the start date of a recurring estimate with the document itself, so the 12 month limit can be checked without guessing.

Not every change can be handled this way in advance. Items or services that could not reasonably have been expected, and that arise during a visit, do not have to be listed in the estimate beforehand. That is different from a change the provider already expects, or has been told about, before the service date. The first belongs in a conversation after the visit, with the reason recorded. The second belongs in a new estimate before the visit. When you are told the plan has changed, ask one question in writing: "Please send my updated Good Faith Estimate, and show what changed from the first one." Save both versions, with the dates you received them, and bring both to any later billing conversation. If you lose one, the regulation treats an issued estimate as part of your medical record and requires the convening provider to give you a copy of any estimate it furnished within the last 6 years when you ask.

One timing rule protects you from a last-minute swap. If the expected provider or facility is replaced less than 1 business day before the service, the replacement must accept, as its own estimate, the estimate that the replaced provider gave for those items. A new anesthesia group assigned the morning of a procedure inherits the old group's figures.

Source: Centers for Medicare and Medicaid Services and U.S. Department of Health and Human Services, FAQs About Consolidated Appropriations Act, 2021 Implementation, Good Faith Estimates for Uninsured (or Self-Pay) Individuals, Part 2, April 5, 2022, checked October 29, 2026; 45 CFR 149.610(b) and (f), checked October 29, 2026.

When the estimate itself contains a mistake

Estimates are prepared by people, and the regulation expects some to be wrong. It does not treat an honest error as a violation by itself: a provider that acted in good faith and with reasonable due diligence does not fail to comply solely because of an error or omission, provided it corrects the information as soon as practicable. The same applies when a provider relied in good faith on information from another entity, unless it knew or reasonably should have known the information was incomplete or inaccurate.

The protection for you sits in the next sentence of each of those paragraphs. If items or services are furnished before an error in the estimate is addressed, the provider may be subject to the patient-provider dispute process when the billed charges are substantially in excess of the estimate. Put simply, a provider can fix a mistaken estimate before your service, and it should send you the corrected version; a mistake that is still on the estimate on the day of service does not cancel your dispute right. If you spot something that looks wrong, such as a missing layer, a code that does not match your order, or a charge that seems to belong to a different service, ask about it in writing before the date, and keep both the question and any corrected estimate.

The $400 dispute rule

If your final bill from a provider or facility is $400 or more above that provider's Good Faith Estimate for the same items and services, you may be eligible to start the federal patient-provider dispute resolution process. You generally must start the process within 120 calendar days of receiving the bill. The Good Faith Estimate checker runs this comparison for you: enter one provider's estimate lines and bill lines, and it totals both, flags the changed lines, and applies the $400 test. Keep the estimate, the bill, and any revised estimates together. The estimate does not freeze the price when the clinical plan legitimately changes on the day, for example when a biopsy is taken, but the changed code and charge should be explainable against the estimate's listed items.

The regulation's definitions make the test more exact than a glance at two totals. "Substantially in excess" means total billed charges at least $400 more than the total expected charges on the estimate for that provider or facility. "Total billed charges" counts all the primary items and everything furnished in conjunction with them, whether or not those items were on the estimate. Two consequences follow. A charge for an item the estimate never mentioned still counts toward the $400. And the test is run provider by provider: a surgeon $250 over and a facility $250 over are two bills each under the line, not one $500 overrun.

This summary is general information. For the current rules, forms, and deadlines, check the CMS No Surprises Act pages and, if needed, a qualified advisor. MyCarePrice does not file disputes on your behalf.

The dispute, from filing to decision

The process is set out in 45 CFR 149.620, and the CMS dispute page adds the practical details the regulation leaves to guidance. Read the steps in order; each has its own clock.

1. Check eligibility. CMS lists the conditions: you did not have or did not use insurance for the care, you told the provider before the care that you were not using insurance, the care was on or after January 1, 2022, you have the provider's estimate, your initial bill is dated within the last 120 calendar days, and one provider or facility charged at least $400 more than its estimate.
2. File the initiation notice. The regulation says it must be postmarked within 120 calendar days of receiving the initial bill, and it must identify the item or service with its date and a description, include a readable copy of the bill and of the estimate, give the provider's contact details if they are not on the estimate, name the state where you received the care, and state how you want to be contacted. You can file online or on paper. CMS says not to mail original documents.
3. Pay the administrative fee. The CMS page lists a $25 non-refundable fee and says the dispute does not start until it is paid. It can be paid online by credit card, PayPal, or Venmo, or by money order or cashier's check with a paper filing.
4. Answer any insufficiency notice. A Selected Dispute Resolution entity, the independent reviewer HHS assigns, checks that the bill is eligible and the notice is complete. If it is not, you get a notice explaining why and 21 calendar days to send supplemental information, extended to 35 days in total if you asked for the notice in an accessible format or another language and did not receive it within 14 calendar days.
5. The provider responds. Once the dispute is found eligible, the provider or facility has 10 business days to send the reviewer its copy of the estimate, the billed charges, and any documentation showing the difference reflects a medically necessary item or service based on unforeseen circumstances that could not reasonably have been anticipated when the estimate was given.
6. The reviewer decides. The reviewer has 30 business days after receiving that information to determine the amount you owe, and the decision is binding on both sides absent fraud or misrepresentation, although the provider can still offer you a lower amount or financial assistance.

While the dispute is pending, the provider must not move the disputed bill into collection or threaten to, must cease collection efforts if it already did, and must suspend late fees on the unpaid amount until the process ends. It also must not take or threaten retributive action against you for using the process. The CMS page adds that your costs will not increase because you filed. Either party may also report that the assigned reviewer has a conflict of interest, and the reviewer then has 3 business days to notify HHS.

Show the steps behind this figure

Step	Who acts	Clock	Source
Bill arrives at least $400 over that provider's estimate	You	Starts the 120 day period	45 CFR 149.620(a)(2)(ii), (c)(1)
File the initiation notice and pay the fee	You	Postmarked within 120 calendar days of receiving the initial bill; $25 fee	45 CFR 149.620(c)(1); CMS dispute page
Eligibility and completeness check	Reviewer	21 calendar days to send supplemental information if insufficient (35 in the accessibility case)	45 CFR 149.620(c)(4)
Send estimate, bill and any documentation	Provider or facility	Within 10 business days	45 CFR 149.620(c)(4)(i), (f)(2)(i)
Payment determination	Reviewer	Within 30 business days of receiving the provider information	45 CFR 149.620(f)(2)(ii)
No collections, no late fees, no retribution	Provider or facility	While the dispute is pending	45 CFR 149.620(c)(5), (c)(6)

How the reviewer sets the amount you owe

The reviewer does not split the difference. The regulation gives it a decision rule for each unique item or service on the bill, and the rule turns on one question: has the provider given credible information that the difference between the billed charge and the estimate reflects the cost of a medically necessary item or service, based on unforeseen circumstances that could not reasonably have been anticipated when the estimate was given? "Credible" is defined as information that, on critical analysis, is worthy of belief and trustworthy.

Situation on the bill	Provider's evidence	Amount the reviewer must set for that item
Item on the estimate, billed at or below the estimate	Not needed	The billed charge
Item on the estimate, billed above it	No credible information	The expected charge on the estimate
Item on the estimate, billed above it	Credible information	The lesser of the billed charge and the median amount plans pay for the same or similar service in the area from an independent database, but not less than the estimate
New item not on the estimate	No credible information	$0
New item not on the estimate	Credible information	The lesser of the billed charge and that median database amount

The reviewer then adds the item amounts together. If that total is lower than the billed charges, the reviewer reduces it by the administrative fee you paid, which is how the CMS page can say the $25 comes off what you owe when you win. The regulation also defines who wins for this purpose: the provider prevails when the amount set equals the billed charges, and you prevail when it is less. Paying part of the bill while the dispute runs does not count as agreeing to that amount.

A labelled illustration shows the arithmetic; the charges are invented for the example and belong to no real provider. Suppose an imaging center's estimate listed one scan at $900 and a reading at $300, a total of $1,200, and the bill shows the scan at $900, the reading at $450, and a new $400 line the estimate never mentioned, a total of $1,750. The bill is $550 over the estimate, so it clears the $400 line. If the center sends no credible explanation for either change, the reviewer must set the scan at its billed $900, the reading at its estimated $300, and the new line at $0: a total of $1,200, which is below the billed $1,750, so the $25 fee comes off and the amount owed is $1,175. If the center does document an unforeseen, medically necessary reason for the new line, that line is set at the lesser of $400 and the database median, and the outcome depends on a number only the reviewer will see. The point of the exercise is the structure: an estimate with codes and line charges is what gives each of those rows a figure to be measured against.

If you and the provider settle before a decision, whether by a lower amount, financial assistance, or your agreement to pay in full, the provider must notify the reviewer within 3 business days and must reduce your settlement amount by at least half the administrative fee. The CMS page puts that at $12.50. If a dispute is decided in your favor and the provider keeps billing you or sends the bill to collections, CMS tells you to submit a complaint to the No Surprises Help Desk.

How to ask

1. State clearly: "I am uninsured" or "I will be self-pay for this service and will not submit it to insurance."
2. Give the CPT code and setting and ask: "Please provide my Good Faith Estimate in writing, listing each of your charges with its code, and tell me which other groups, such as anesthesia or pathology, will bill me separately."
3. Ask who the convening provider is when more than one provider will bill, which groups its estimate includes, and request a separate estimate from each group it leaves out.
4. Save the estimate with the date you received it. Bring it to the billing conversation if the final bill differs.

How this relates to a cash quote

A cash quote you negotiate by phone and a Good Faith Estimate serve the same purpose: a written price before service. If you are uninsured or self-pay, ask that the written cash price be provided as your Good Faith Estimate so the $400 dispute protection attaches. Either way, confirm your price in writing before service. For the full no-insurance worksheet that runs code, anchor, cash price, estimate, and setting comparison in one order, see How to price a procedure without insurance.

The regulation also explains why a discounted cash price is the right figure to ask for. It defines the expected charge on an estimate for a self-pay person as the cash pay rate or rate the provider has established for uninsured or self-pay individuals, reflecting any discounts for them. An estimate built on the provider's undiscounted list charge, when the provider has a self-pay rate, is a question worth asking before you book.

How to use the estimate with the anchors on this site

When the estimate arrives, check it in three passes. First, match every code on the estimate to the code on your order and to the procedure page for that test. A code you do not recognize is a question to ask before service, not after the bill. Second, account for every billing layer: professional, facility, anesthesia, and pathology should each appear on this estimate, on a separate estimate from the group that bills it, or be confirmed as not applicable. Third, compare the order of magnitude with the verified Medicare anchor for that code. The anchor is not your price, but a facility layer many times the anchor is a prompt to ask what the payment system and inclusions are. The Price Anchor Explorer makes that third pass quick.

Keep the estimate, any revised estimate, and the final bill together. If the bill exceeds the estimate, the dispute question is specific: is it $400 or more above the estimate from that provider for the same items and services, and are you inside the filing window? Write those dates down the day the bill arrives. Prices only, no legal advice: for the current rules and forms, use the CMS No Surprises Act pages or a qualified advisor.

A scheduled birth is a good test of the estimate rules, because it has several layers to account for; the birth bill guide lists them so an estimate can be read line by line.

The estimate rules in this guide are for people who do not use insurance. For people who do, the protections run the other way and are set out in the guide to No Surprises Act protections for insured patients, including the separate notice and consent form that a nonparticipating clinician must use. A planned admission without insurance is where an estimate matters most, and the hospital stay guide lists what to ask for. If a bill is correct but still more than you can pay, a dispute is the wrong tool; hospital financial assistance is the route the CMS dispute page itself points uninsured patients to.

Two services show the recurring and per-unit sides of an estimate. Weekly therapy can be covered by one estimate of up to 12 months, as the therapy cost guide explains, and an allergy testing estimate should list each code with its unit count, as the allergy testing guide shows.

Good Faith Estimate questions

Where the estimate rules come from

Centers for Medicare and Medicaid Services, Medical bill rights, the CMS No Surprises Act consumer pages for people who do not have or do not use insurance, checked October 29, 2026. Centers for Medicare and Medicaid Services, FAQs About Consolidated Appropriations Act, 2021 Implementation, Good Faith Estimates for Uninsured (or Self-Pay) Individuals, Part 2, April 5, 2022, checked October 29, 2026. Centers for Medicare and Medicaid Services, Learn more about the Good Faith Estimate and the Patient-Provider Dispute Resolution process for people without insurance or who plan to pay for the costs themselves, dated December 21, 2021, checked October 29, 2026. HHS, Good Faith Estimates FAQs, Part 4, December 27, 2022, on abbreviated estimates during the co-provider enforcement discretion, checked October 29, 2026.

• eCFR, 45 CFR 149.610, requirements for Good Faith Estimates for uninsured (or self-pay) individuals: definitions, deadlines, content, form, record keeping and error provisions. Text current as of October 27, 2026; checked October 29, 2026.
• eCFR, 45 CFR 149.620, the patient-provider dispute resolution process: the $400 definition, initiation, collection protections, payment determination and the administrative fee. Text current as of October 27, 2026; checked October 29, 2026.
• CMS, Dispute a medical bill, eligibility list, the $25 fee and the $12.50 settlement reduction. Page last modified October 2, 2026; checked October 29, 2026.
• CMS, What is a good faith health insurance estimate?, delivery timing and the single-provider description. Page last modified October 5, 2026; checked October 29, 2026.
• HHS, FAQs About Consolidated Appropriations Act, 2021 Implementation - Good Faith Estimates for Uninsured (or Self-Pay) Individuals, Part 3, December 2, 2022, on enforcement discretion for co-provider and co-facility charges. Checked October 29, 2026.
• Federal Register, document search for rules and proposed rules published since January 1, 2023 that mention "good faith estimate" and "co-provider": no results on October 29, 2026.

General billing information, not legal advice. Prices only on this site: no diagnosis or treatment advice. Confirm your price in writing before service.