Few things damage patient trust faster than an unexpected medical bill. For years, patients received large charges they never saw coming, from out-of-network providers they never chose or from services they were never told about. The No Surprises Act, which took effect in 2022, was created to stop this. It places new responsibilities on providers, facilities, and billing teams, and mistakes can lead to patient disputes, penalties, and lost revenue.

For medical practices, the key is understanding which rules apply to which patients and building workflows that make compliance routine. This article explains the law in practical terms, covers Good Faith Estimates in detail, highlights the errors billing teams make most often, and shows how to protect both your patients and your practice.

Note: Federal rules and enforcement guidance evolve, so practices should confirm current requirements with official CMS resources or qualified legal counsel.

What the No Surprises Act Covers

The No Surprises Act addresses several different situations, and billing teams often confuse them. In general terms, it does two main things.

1. Protects patients from surprise out-of-network bills. In certain situations, patients with insurance cannot be balance billed beyond their normal in-network cost sharing. These include emergency services, and certain non-emergency services provided by out-of-network clinicians at in-network facilities. Examples include an out-of-network anesthesiologist or radiologist at an in-network hospital. Air ambulance services are covered as well.

2. Requires Good Faith Estimates for uninsured and self-pay patients. Providers must give these patients an estimate of expected charges before scheduled care. This is the part that affects most outpatient practices directly.

Understanding this split matters. A practice that treats both situations as one rule will either over-comply in places it does not need to or miss obligations it does have.

What Is a Good Faith Estimate?

A Good Faith Estimate (GFE) is a written notice of the expected charges for scheduled items and services. It applies to patients who are uninsured or who choose not to use their insurance for a service. The estimate should include the expected charges for the primary service and for related items that are reasonably expected, such as facility fees, lab work, or other services tied to the visit.

A compliant GFE generally includes:

• The patient's name and contact details
• A description of the primary service or item, and the date it is scheduled
• Itemized expected charges, with service codes where applicable
• The name, tax identification number, and national provider identifier of the provider or facility
• A disclaimer explaining that the estimate is not a contract and that the patient may have dispute rights
• Any other required notices

Timing Rules for Good Faith Estimates

Timing is where many practices slip. In general:

• If an appointment is scheduled at least 10 business days in advance, the estimate is due within 3 business days of scheduling.
• If an appointment is scheduled 3 to 9 business days in advance, the estimate is due within 1 business day of scheduling.
• If a patient requests an estimate before scheduling, it is due within 3 business days of the request.
• For appointments scheduled fewer than 3 business days ahead, an estimate is generally not required at scheduling, though practices still benefit from providing pricing information.

Practices should confirm these timeframes against current federal guidance and build alerts into their scheduling workflow so the clock is never missed.

Where Professional Support Makes a Difference: Mednex Group

Good Faith Estimate compliance touches scheduling, front-desk communication, coding, fee schedules, and documentation. When one piece is missing, the entire process fails. Many practices find that structured medical billing services reduce this risk by tying estimate creation to the scheduling workflow, maintaining accurate fee schedules, and keeping records that show the practice acted in good faith.

Mednex Group supports practices by aligning front-end processes with back-end billing, so that the amounts quoted to patients reflect real coding and pricing, and so that any later difference between the estimate and the final bill can be explained and documented. This matters because the estimate is the benchmark against which a patient's final bill is judged.

The Patient-Provider Dispute Resolution Process

The law gives uninsured and self-pay patients a way to challenge bills that are substantially higher than the estimate. If the billed charges are at least $400 more than the Good Faith Estimate from a provider or facility, the patient may start a federal dispute resolution process, generally within 120 days of receiving the bill.

In that process, an independent reviewer examines the estimate and the final bill. If the provider cannot justify the difference, the patient may only be required to pay the estimated amount or a figure the reviewer determines. This makes the accuracy of your original estimate extremely important. A sloppy or missing estimate leaves the practice with weak evidence and a real risk of losing revenue.

To protect yourself:

• Keep a copy of every estimate sent, with the date and method of delivery.
• Record any change in services and send an updated estimate when the scope changes.
• Document clinical reasons for added services, so differences can be justified.
• Train staff to explain that an estimate is an expectation of charges and not a guarantee.

Common Mistakes Billing Teams Make

1. Not identifying self-pay patients at scheduling. If the front desk does not flag uninsured or self-pay patients, no estimate gets generated.

2. Missing the delivery deadline. An accurate estimate delivered late is still a compliance failure.

3. Leaving out related services. Estimates should reflect items reasonably expected as part of the visit. Omitting labs, imaging, or facility fees leads to large variances later.

4. Using outdated fee schedules. If prices change but the estimate template does not, the numbers will not match the final bill.

5. Poor recordkeeping. Without proof of delivery and timing, a practice cannot defend itself in a dispute.

6. Confusing estimates with insurance benefit explanations. A Good Faith Estimate applies to uninsured and self-pay patients, not to insured patients using their benefits.

7. Failing to update estimates when care changes. If services are added or changed, a new or revised estimate may be needed.

8. Treating the notice as optional. Required consumer notices about billing protections must be posted and available, not just stored in a drawer.

Connecting Compliance to Revenue Cycle Management

Good Faith Estimates are not only a compliance exercise. They sit at the front of your billing process and influence everything that follows. Strong revenue cycle management treats price transparency, eligibility checks, patient financial conversations, and final collections as parts of one connected system.

When estimates are accurate, patients know what to expect, which improves the odds they will pay on time and reduces angry calls to the front desk. Accurate estimates also reduce write-offs caused by disputes and by patients who refuse to pay what they feel they were never warned about. In addition, the data from estimates reveals useful patterns. Practices can see which services trigger the largest variances, which patients are most likely to need payment plans, and where pricing may need review.

In short, compliance and revenue protection point in the same direction. A practice that builds clear estimate workflows usually collects more and argues less.

Insured Patients and Balance Billing Protections

While Good Faith Estimates focus on uninsured and self-pay patients, billing teams also need to understand the protections for insured patients. When the law applies, a patient receiving covered emergency care or certain services from an out-of-network provider at an in-network facility should only owe their in-network cost sharing, such as the copay, coinsurance, or deductible.

For providers, this means:

• Not sending balance bills for the difference above the allowed amount in protected situations
• Working with the payer through the claim payment and, if needed, the federal independent dispute resolution process for payment disputes
• Reviewing consent rules carefully, since some non-emergency situations allow a patient to knowingly waive protections only under strict conditions

These are specialized areas where mistakes can be costly, so many practices rely on experienced billing professionals who monitor payer behavior and handle disputes properly.

Building a Compliant Workflow

A reliable process does not need to be complicated. Consider this simple structure:

1. At scheduling, identify whether the patient is insured, uninsured, or self-pay.
2. Flag eligible patients in the system so an estimate task is created automatically.
3. Build the estimate using current fee schedules and expected related services.
4. Deliver it on time, in writing, in the format the patient requested.
5. Save a copy with the date, time, and delivery method.
6. Compare the final bill to the estimate before sending it out.
7. Document and explain any difference, and issue an updated estimate if care changed.
8. Audit regularly to confirm deadlines are being met.

Assigning clear ownership for each step prevents the common problem where everyone assumes someone else handled it.

Frequently Asked Questions

1. Who must receive a Good Faith Estimate?
Uninsured patients and patients who choose not to use their insurance for a service must receive one when care is scheduled, or when they request pricing information.

2. Does a Good Faith Estimate guarantee the final price?
No. It is an estimate of expected charges, but if the final bill is at least $400 higher than the estimate from that provider or facility, the patient may start a dispute resolution process.

3. How quickly must the estimate be delivered?
It depends on how far ahead the appointment is scheduled. Generally it is due within one to three business days of scheduling or of the patient's request. Confirm current timing with official guidance.

4. Are insured patients covered by the No Surprises Act?
Yes, in specific situations, such as emergency care and certain out-of-network services at in-network facilities, where balance billing is restricted.

5. What records should a practice keep?
Keep a copy of each estimate, proof of delivery and timing, and documentation of any changes to the planned care or related services.

6. Can a billing company help with No Surprises Act compliance?
Yes. A billing partner can support estimate creation, fee schedule accuracy, recordkeeping, claim review, and dispute handling, though the practice remains responsible for its legal obligations.

Final Thoughts

The No Surprises Act changed expectations for transparency in healthcare billing. Practices that treat Good Faith Estimates as a routine, well-documented part of scheduling will protect their patients, reduce disputes, and keep revenue steady. Practices that ignore the rules risk penalties, frustrated patients, and unpaid balances.

If your team needs a clearer process for estimates, documentation, and compliant billing, Mednex Group can help you put the right systems in place so that every patient knows what to expect and every claim is ready to be paid.