What Is a Good Faith Estimate? No Surprises Act Rule

Medical bills are notoriously difficult to predict. A procedure that seems straightforward can generate charges from multiple providers, laboratories, and facilities—often with little advance warning of what each will cost. The No Surprises Act addressed this problem in part by creating the Good Faith Estimate (GFE) requirement. If you are uninsured or paying out of pocket, this rule gives you the right to know what your care will cost before you receive it.

What Is a Good Faith Estimate?

A Good Faith Estimate (GFE) is a written cost estimate that healthcare providers are required to give you in advance of scheduled services. It is not a binding contract or a final bill—but it is a formal document that triggers real legal rights if your actual bill significantly exceeds what was estimated.

The GFE requirement took effect January 1, 2022 under the No Surprises Act.

Who Is Entitled to a Good Faith Estimate?

GFE rights apply to:

• Uninsured patients. Anyone who does not have health insurance coverage.
• Self-pay patients. Anyone who has insurance but is paying for a particular service out of pocket without using their insurance (for example, services not covered by their plan, or patients who choose not to file with insurance).

If you have insurance and are using it, the GFE right works differently—insurers are required to provide cost estimates through their own transparency tools (under separate rules), but the GFE dispute process described below applies specifically to uninsured and self-pay patients.

Important note: You can ask your provider for a GFE even if you have insurance, but the dispute protections only apply if you are not using insurance for the service.

What Must a Good Faith Estimate Include?

A complete GFE must include:

• Patient name and date of birth
• Description of the primary service being scheduled
• Itemized list of expected charges including: the service itself, facility fees, anesthesia (if applicable), laboratory tests ordered, diagnostic imaging, and any expected ancillary services
• Diagnosis and procedure codes (ICD-10 and CPT codes)
• Name and location of the provider or facility issuing the estimate
• Expected date of service
• Total estimated cost

The GFE should also include estimates for co-providers—other physicians or services expected to be part of your care. This is where the rule gets complicated: the primary provider is responsible for requesting estimates from co-providers (like anesthesiologists or radiologists) and including them. In practice, co-provider estimates are not always included, which is a compliance issue.

When Must You Receive It?

The timing requirement depends on how far in advance you schedule:

• Scheduled at least 3 business days in advance: GFE must be provided at least 1 business day before the service.
• Scheduled at least 10 business days in advance: GFE must be provided within 3 business days of scheduling.
• Upon request (no scheduled service yet): Provider must deliver the GFE within 3 business days of your request.

You can request a GFE at any time from any provider, even if you are just comparing costs before making a decision.

What If Your Bill Is $400 or More Over the Estimate?

This is the most consequential part of the GFE rule. If your actual bill is at least $400 higher than what was stated in your Good Faith Estimate, you have the right to use the Patient-Provider Dispute Resolution (PPDR) process to challenge the excess charges.

The $400 threshold applies per item or service—not to the total bill. If a single line item is $400+ over its estimated amount, that triggers the right.

What Is the PPDR Process?

The Patient-Provider Dispute Resolution (PPDR) process is a federal administrative process you can initiate to challenge a bill that substantially exceeds your Good Faith Estimate.

How to initiate PPDR:

1. You must initiate within 120 calendar days of receiving your initial bill.
2. Submit a dispute through the federal PPDR portal at cms.gov (search "patient-provider dispute resolution").
3. Pay a $25 administrative fee.
4. Select a certified PPDR entity—a neutral third party that will review the dispute.

What happens next:

• You submit the GFE, the actual bill, and any relevant documentation.
• The provider submits their justification for the higher charges.
• The PPDR entity reviews both sides and issues a binding decision—either upholding the GFE amount or finding the higher charges are justified.
• The losing party bears the cost of the PPDR administrative fee.

Important limitation: You must not have already paid the disputed amount. If you paid the bill before initiating PPDR, you may have waived your dispute rights.

Practical Tips

• Request the GFE in writing before every scheduled uninsured or self-pay service, no matter how routine.
• Save the GFE alongside all subsequent bills. You cannot dispute without the estimate.
• Do not pay a bill you intend to dispute before completing PPDR.
• If a provider refuses to provide a GFE, that is a federal compliance violation. You can file a complaint with CMS through the No Surprises Help Desk at 1-800-985-3059.

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Related Reading:

• How to Write an Insurance Appeal Letter
• What Is Medical Necessity?
• Internal vs External Insurance Appeal