You Have the Right to Know What Your Care Will Cost — Before You Receive It
Imagine walking into a restaurant where there are no prices on the menu. You order dinner, enjoy your meal, and then the waiter hands you a bill for $4,000. You would be outraged. You would demand to know the prices before ordering. Yet this is exactly how the American healthcare system has operated for decades — until the Good Faith Estimate provision of the No Surprises Act changed the rules.
Since January 1, 2022, if you are uninsured or plan to self-pay for a medical service, you have the legal right to receive a written estimate of all expected charges before your appointment or procedure. And if the final bill exceeds that estimate by $400 or more, you can dispute it through a formal federal process.
This is one of the most powerful and underutilized patient rights in American healthcare. In my practice, I have used Good Faith Estimates to save clients thousands of dollars — and in some cases, to help them choose a different, more affordable provider before the service even takes place.
Who Can Request a Good Faith Estimate?
You are eligible to request a GFE if you are:
Uninsured — you do not have any health insurance coverage
Self-pay — you have insurance but choose not to use it for a particular service (perhaps because the out-of-pocket cost is lower without insurance, or the service is not covered)
Important clarification: If you have insurance and plan to use it, the GFE requirement does not technically apply. However, you can still ask any provider for a cost estimate, and many will provide one. The formal GFE protections (including the dispute process) only apply to uninsured and self-pay patients.
What Must Be Included in a Good Faith Estimate?
A proper GFE must include:
Patient name and date of birth
Description of the primary service — being scheduled
Expected charges from the scheduling provider — (itemized by service)
Expected charges from any other providers — involved in the care (anesthesiologist, radiologist, lab, etc.)
Diagnosis codes — (ICD-10) and **service codes** (CPT/HCPCS) for each item
The date the estimate was issued
A disclaimer — that the actual charges may differ and information about the dispute process
The requirement that the GFE include charges from all providers involved is critical. One of the biggest sources of surprise bills has always been ancillary providers — the anesthesiologist you did not know would be involved, the pathologist who analyzed your biopsy, the assistant surgeon who was called in. The GFE is supposed to capture all of these charges in advance.
How to Request a Good Faith Estimate
For Scheduled Services
When you schedule a medical service, the provider is required to give you a GFE:
Within 1 business day — if the service is scheduled at least 3 business days in advance
Within 3 business days — if the service is scheduled at least 10 business days in advance
You can also request a GFE at any time, even before scheduling. Simply call the provider's office and say:
"I am an uninsured [or self-pay] patient and I would like to request a Good Faith Estimate under the No Surprises Act for [describe the service]. Please provide a written estimate that includes all expected charges from all providers who will be involved in my care."
For Shopping and Comparing
One of the best uses of the GFE is comparison shopping. You can request GFEs from multiple providers for the same service and compare them side by side. I have seen price differences of 300-500% for the same procedure at different facilities in the same city.
Real example: A client needed a knee MRI. She requested GFEs from three facilities:
Hospital-based imaging center: $2,800
Independent imaging center A: $650
Independent imaging center B: $450
Same MRI. Same quality. The hospital-based center was charging more than six times what the independent center charged. Without the GFE process, she would have gone to the hospital center her doctor recommended and paid $2,800.
The $400 Rule: Your Right to Dispute
Here is where the GFE becomes truly powerful. If your final bill exceeds the Good Faith Estimate by $400 or more, you have the right to dispute the bill through the Patient-Provider Dispute Resolution (PPDR) process.
This is a formal, federally administered process:
**You receive a bill** that is $400+ higher than your GFE
**You initiate a dispute** within 120 days of receiving the bill by contacting the provider and the Department of Health and Human Services (HHS)
**A dispute resolution entity** reviews the case
**The entity makes a determination** — if they side with you, the provider must accept the GFE amount (or a modified amount determined by the entity)
The dispute process is designed to be accessible to patients without requiring an attorney. HHS provides instructions and forms on their website.
What Counts Toward the $400 Threshold
The $400 difference is calculated based on the total billed amount compared to the total estimated amount on the GFE. This includes charges from all providers listed on the estimate.
| GFE Estimate | Final Bill | Difference | Can You Dispute? |
|---|---|---|---|
| $2,000 | $2,350 | $350 | No — under $400 threshold |
| $2,000 | $2,400 | $400 | Yes — meets $400 threshold |
| $5,000 | $7,500 | $2,500 | Yes — exceeds $400 threshold |
| $800 | $1,500 | $700 | Yes — exceeds $400 threshold |
Providers Who Do Not Comply
Despite the legal requirement, many providers are not yet fully compliant with the GFE rules. Common issues include:
Not providing a GFE at all — when requested
Providing an incomplete GFE — that does not include charges from all involved providers
Providing the GFE too late — (after the service has already been scheduled or performed)
Significantly underestimating charges — to make the estimate look attractive, then billing much more
If a provider refuses to provide a GFE or provides an inadequate one, you can:
**File a complaint with HHS** at 1-800-985-3059 or online at cms.gov/nosurprises
**File a complaint with your state Department of Insurance** or state health department
**Document the refusal** in writing and reference it in any subsequent billing dispute
Strategic Uses of Good Faith Estimates
Beyond the basic right to receive an estimate, here are strategic ways to use GFEs:
Negotiate before the service. If you receive a GFE that seems high, use it as a starting point for negotiation. "I received your Good Faith Estimate of $3,500 for this procedure. I have also received estimates from other facilities in the range of $1,200-$1,800. Can you match a more competitive price?"
Lock in a price. Once you have a GFE, the provider is essentially locked into that price (within $400). This gives you certainty about what you will owe, which is rare in healthcare.
Identify unnecessary services. Reviewing the GFE before your procedure gives you the opportunity to ask questions about each listed service. "I see a charge for a pre-operative lab panel. Is that medically necessary for this procedure, or is it optional?"
Build a paper trail. If you end up disputing the bill later, having a GFE on file strengthens your case significantly. It shows that the provider committed to a specific price and then exceeded it.
Good Faith Estimates and Insurance
While the formal GFE protections apply only to uninsured and self-pay patients, there is a growing movement to extend similar protections to insured patients. Several states have enacted their own cost transparency laws that go beyond the federal requirements.
Even if you have insurance, you can and should ask for cost estimates before any significant procedure. Many insurance companies also offer cost estimator tools through their websites and apps that can give you an idea of what you will owe based on your specific plan.
Pro tip: If you have a high-deductible health plan and have not met your deductible, you are essentially paying out of pocket for most services. In this situation, it may be worth asking the provider if you can get a better price by paying as a self-pay patient rather than running the charge through your insurance. Some providers offer self-pay rates that are lower than the insurance-negotiated rate minus your deductible.
Key Takeaways
Uninsured and self-pay patients have a legal right — to a Good Faith Estimate before any scheduled service
The GFE must include charges from all providers — involved in your care, not just the scheduling provider
If your bill exceeds the GFE by $400 or more — , you can dispute it through the federal PPDR process
Use GFEs to comparison shop — price differences of 300-500% for the same service are common
Request GFEs in writing — and keep them for your records
Providers who refuse to provide a GFE — are violating federal law — file a complaint with HHS
Even insured patients — should ask for cost estimates before significant procedures
The GFE is a negotiation tool — use it to lock in prices and identify unnecessary charges