Good Faith Estimates Under the No Surprises Act

CareCostIndex

If you’re paying for care without using insurance — either because you’re uninsured or electing to self-pay — federal law gives you the right to a written price estimate before a non-emergency procedure. If the final bill exceeds that estimate by a meaningful margin, you can dispute it through a federal process.

When you’re entitled to a Good Faith Estimate

Since January 1, 2022, under the No Surprises Act:

If you are uninsured, or are insured but chose not to submit a claim to your insurance for a scheduled service, you are entitled to a written Good Faith Estimate (GFE) before the service.
Providers must offer the GFE automatically when a service is scheduled 3+ business days in advance, and on request in all other cases.
The GFE must cover all reasonably expected items and services for the primary procedure — including anesthesiology, facility fees, labs, and anything else the provider can foresee.

(If you are insured and using your insurance, the parallel protection is the Advanced Explanation of Benefits (AEOB), which insurers are phasing in separately.)

What a GFE must include

Your name and date of birth.
Description of the service, with dates.
Itemized list of items and services, including CPT codes and expected charges for each.
Name, NPI (National Provider Identifier), and tax ID of each provider and facility.
Diagnosis codes, if available.
Expected service locations.
The required disclaimer language: notice that this is only an estimate, that the actual items or services may change, that you have the right to initiate Patient-Provider Dispute Resolution if the bill exceeds the estimate by more than $400, and plain-language contact information for disputes.

If any of these required elements are missing, the estimate is non-compliant and you can ask for a corrected one.

Timing

The GFE must be delivered to you before the service, within these windows:

Service scheduled at least 10 business days in advance: GFE within 3 business days of scheduling.
Service scheduled 3–9 business days in advance: GFE within 1 business day of scheduling.
Service scheduled less than 3 business days out: no GFE required unless you request one.
On request at any time (even without a scheduled service): 3 business days.

The Patient-Provider Dispute Resolution (PPDR) process

If the final bill for the scheduled service exceeds the Good Faith Estimate by more than $400, you can initiate PPDR through the federal portal. The highlights:

Deadline: you have 120 days from receiving the bill to start a dispute.
Fee: currently $25 for the patient, refunded if the patient prevails.
Where: cms.gov/nosurprises.
Who decides: a Selected Dispute Resolution Entity (SDR), which is an independent third party certified by HHS. The SDR reviews the GFE, the bill, and any evidence both sides submit.
Outcome: the SDR determines a binding payment amount. It’s typically either the Good Faith Estimate amount (if the excess was unjustified) or the median in-network rate for that service (if the excess was partially justified).

What counts as “the scheduled service”

The GFE covers what the provider could reasonably foresee at the time of scheduling. If complications during a surgery lead to additional unrelated procedures — a genuinely unforeseen event — those may be billed separately without a new GFE. But “reasonably foreseeable” is interpreted broadly: ancillary services like anesthesia, expected pathology, and post-op visits should all be in the estimate.

If you are given a GFE that seems suspiciously narrow (a surgeon’s professional fee only, with no facility, anesthesia, or lab lines), push back: “Please provide a GFE that includes all reasonably expected services, not just your professional fee.”

Practical checklist

When you schedule a self-pay procedure, ask for the Good Faith Estimate explicitly: “Under the No Surprises Act, I’d like the Good Faith Estimate for this service.”
When you receive it, check that it covers everything you can foresee: surgeon, facility, anesthesia, pathology, imaging, post-op.
Keep the GFE. Compare it line-for-line to the eventual itemized bill.
If the final bill exceeds the GFE by more than $400, consider PPDR. Even the threat of PPDR often gets the provider to adjust the bill voluntarily.
If the provider refuses to produce a GFE at all, file a complaint at cms.gov/nosurprises.

For insured patients: the AEOB

Insurers are gradually rolling out Advanced Explanations of Benefits (AEOBs), which do for insured patients what GFEs do for self-pay patients: pre-service, itemized, good-faith estimate of costs specific to your plan and network. Federal rules require AEOBs for most commercial plans, but staged implementation means coverage in 2026 is uneven. Ask your insurer whether an AEOB is available for your upcoming procedure.

Good Faith Estimates sit alongside the other patient protections in the No Surprises Act:

Ban on balance billing for emergency services and for out-of-network ancillary providers at in-network facilities (see our guide).
Ban on balance billing for air ambulance transport.
Clear notice-and-consent requirements for the limited situations where out-of-network balance billing is still permitted.

Bottom line

The Good Faith Estimate is the closest thing U.S. patients have to a legally enforceable price guarantee. Use it: request one, keep it, compare it to the final bill, and invoke dispute resolution if necessary. For many families, the ability to set and enforce a price before the procedure is the single biggest protection the No Surprises Act added.

Reviewed by CareCostIndex Editorial Team · Last reviewed: 2026-04-16