The “No Surprises Act” & Good Faith Estimates

(Required Federal Notice for All Clients)

Overview

The No Surprises Act was passed in December 2020 under Section 2799B-6 of the Public Health Service Act to protect consumers from unexpected medical bills.

Beginning January 1, 2022, the law requires all healthcare providers — including mental health clinicians — to provide clients who are not using insurance (or who are using out-of-network benefits) with a Good Faith Estimate of expected charges for services.

As a Licensed Clinical Mental Health Counselor in Vermont, I am committed to transparency, fairness, and ensuring that you have clear information about the cost of your care.

What Is a Good Faith Estimate?

A Good Faith Estimate (GFE) outlines the anticipated total cost of non-emergency healthcare services.

It is intended to promote predictability and transparency around therapy costs before services begin.

A Good Faith Estimate:

  • Covers all regularly scheduled therapy sessions and agreed-upon services.

  • Does not include unexpected or unscheduled services (e.g., crisis sessions, late cancellations, or no-shows).

  • May include additional services or administrative fees if scheduled in advance, such as consultations with collateral contacts, report writing, or extended documentation requests.

In my practice, I provide Good Faith Estimates that project up to 12 months in advance, based on my current rates and the session frequency we discuss together. Your estimate gives you a clear sense of what to expect over the course of a year of therapy.

Your Rights as a Client

You have specific rights under the No Surprises Act and the Good Faith Estimate provision:

  • You have the right to receive a Good Faith Estimate of expected charges before starting any non-emergency healthcare service.

  • You have the right to request a Good Faith Estimate before scheduling an appointment.

  • You are entitled to a written Good Faith Estimate at least 1 business day before your scheduled service if it’s booked 3–9 business days in advance, or within 3 business days if scheduled at least 10 business days ahead.

  • You have the right to receive an updated Good Faith Estimate if service frequency, scope, or rates change.

  • You have the right to dispute any bill that exceeds your Good Faith Estimate by $400 or more through a federal dispute resolution process.

  • You should keep a copy of your Good Faith Estimate for your records.

For more information about your rights, visit the federal site: www.cms.gov/nosurprises.

Important Considerations & Disclaimers

  • A Good Faith Estimate is exactly that — an estimate. Actual costs may vary depending on session length, frequency, or changes to your treatment plan.

  • For new clients, I may update your estimate after our initial sessions, once we have a clearer understanding of your goals, needs, and frequency of care.

  • The Good Faith Estimate is not a contract and does not obligate you to continue services.

  • Federal law currently does not allow clients to waive their right to receive a Good Faith Estimate.

  • I am required by law to issue a new Good Faith Estimate every 12 months for all ongoing clients. You’ll be asked to acknowledge receipt of each updated estimate so we remain compliant with federal regulations.

Questions or Concerns

If you have any questions about your Good Faith Estimate, how fees are calculated, or how this law applies to your care, please don’t hesitate to reach out to me.

You can also find additional guidance about your rights under the No Surprises Act at:
👉 www.cms.gov/nosurprises

Jennifer Kerns, MA, LCMHC
Licensed Clinical Mental Health Counselor — Vermont
Private Practice, Burlington, VT