Short answer: When patients at your cosmetic clinic don’t have or use health insurance, CMS says providers usually have to give them a good faith estimate of expected charges. They get it when they schedule care at least 3 business days ahead, or when they ask for one. The federal rule also requires that information about this right be displayed on the provider’s or facility’s website, in the office and where patients schedule or ask about costs.
Before you read: We based this guide on 45 CFR 149.610, the federal rule for good faith estimates under the No Surprises Act. We also used the pages and guidance of the Centers for Medicare & Medicaid Services (CMS). A Consumer Financial Protection Bureau (CFPB) answer on medical credit cards adds the note on insurance. We read them on November 10, 2026. Whether a treatment needs an estimate depends on who provides it and on the patient’s coverage. It is general information, not legal advice.
Which patients get a good faith estimate
The rule calls them uninsured (or self-pay) individuals. That includes a patient who doesn’t have benefits for the item or service under any of the plans it names. Those are group health plans, health insurance coverage, federal health care programs and Federal Employees Health Benefits (FEHB) plans.
It also includes a patient with benefits under a group health plan or health insurance coverage who does not seek to have a claim for the item or service submitted.
CMS tells patients they may choose not to use insurance if the service they need isn’t covered, or if paying out of pocket costs less.
The CFPB notes medical credit cards have traditionally covered procedures insurance didn’t, such as cosmetic procedures. Our guide to cosmetic surgery financing covers those plans and how to advertise them.
CMS’s fact sheet on what counts as health insurance adds an exception. People covered by a federal health care program, such as Medicare or Medicaid, aren’t entitled to this estimate, even if the program doesn’t cover the item or service.
To find out, the rule has the provider that schedules the care ask whether the patient is enrolled in a plan or coverage. If they are, it asks whether they want a claim submitted for the main item or service.
In its FAQ, the Department of Health and Human Services (HHS) suggests providers may wish to discuss whether the patient expects their plan may not cover certain items or services.
In our view, ask both questions every time a patient books a treatment, and note the answers in the patient’s file.
Who has to give the estimate
The rule sets requirements for health care providers and facilities. A provider is a physician or other health care provider acting within the scope of their license or certification under state law.
A facility is a licensed or approved institution, such as a hospital, an ambulatory surgical center, a laboratory or an imaging center.
HHS’s FAQ says that, generally, every provider and facility that schedules care for an uninsured (or self-pay) patient, or gets a request from one, has to give the estimate.
It adds that no specific specialties, facility types or sites of service are exempt.
Neither the rule nor the CMS pages cited here name med spas. The rule’s requirements apply to providers and facilities as it defines them.
When the estimate is due
The rule sets the deadlines by how far ahead the care is scheduled. For care scheduled at least 3 business days ahead, the estimate goes out no later than 1 business day after scheduling.
For care scheduled at least 10 business days ahead, it goes out no later than 3 business days after scheduling. When a patient asks for one, the deadline is 3 business days after the request.
The rule treats any discussion or question about the potential costs of care under consideration as a request for an estimate. CMS tells patients they don’t need to use the term “good faith” to ask.
CMS’s fact sheet says an estimate is due upon request, or for care scheduled 3 or more business days ahead. Without a request, it isn’t required for walk-in appointments or care scheduled 1 or 2 business days in advance.
If the scope changes, such as the expected charges, items, providers or facilities, the rule requires a new estimate. It goes out no later than 1 business day before the scheduled date.
For recurring treatments, the rule allows a single estimate that shows the expected scope, such as timeframes, frequency and the total number of treatments. That estimate can’t cover more than 12 months.
In our view, send the estimate on the day the patient books, even when the rule gives you more time.
What goes in the estimate
The rule requires a written estimate, on paper or electronically, as the patient asks. An electronic estimate has to be one the patient can save and print.
HHS’s FAQ gives the patient portal and email as examples of electronic delivery. If the patient asks to get it by phone or in person, the provider may give the information orally, then has to follow up in writing.
The rule lists what the estimate includes: the patient’s name and date of birth, and a description of the main item or service in clear and understandable language. Then come the expected items and services, grouped by provider or facility.
Each item carries its diagnosis codes, expected service codes and expected charges. Each provider or facility appears with its name, National Provider Identifier, Tax Identification Number and the location where the care will happen.
CMS tells patients that, currently, an estimate lists the expected charges of a single provider or facility, even when several are involved. Its example is a surgery, with an estimate from the surgeon and another from the hospital.
The disclaimers say the estimate isn’t a contract and that actual items, services or charges may differ. They also mention items the provider may recommend that are scheduled separately, and the patient’s right to dispute a bill substantially above the estimate.
The rule defines the expected charge as the cash pay rate, or the rate set for uninsured (or self-pay) patients, with any discounts for them.
Asked whether hospitals that offer a set price still owe an estimate, HHS answers yes. It says the actual billed charges may not reflect the set price, and a dispute needs the estimate to begin.
Our pricing page guide covers how to show prices on your site.
In our view, take the prices on your site and the charges in your estimates from the same price list.
The rule makes each estimate part of the patient’s medical record. On request, the provider gives a copy of any estimate issued in the last 6 years.
The notice on your website
The rule requires the provider to tell every uninsured (or self-pay) patient that an estimate is available, when they schedule care or ask for one.
That information has to be written in a clear and understandable manner. It has to be prominently displayed (and easily searchable from a public search engine) on the website, in the office and on-site where scheduling or questions about cost happen.
It is also given orally when a patient schedules care or asks about costs. It has to be available in accessible formats, and in the languages spoken by the people considering or scheduling care with the provider.
CMS publishes a model notice, “Right to Receive a Good Faith Estimate of Expected Charges”, with blanks the provider fills in. HHS considers using it good faith compliance with the duty to inform patients, and using it isn’t required.
The model notice tells patients they can dispute a bill that is at least $400 more than the estimate from that provider or facility.
If your patients book online, our online booking guide covers what to set up on that page.
In our view, give the notice its own page in plain text, and link it from each procedure page and from the booking page.
When the bill is higher than the estimate
CMS says an uninsured (or self-pay) patient who gets a bill at least $400 more than the expected charges on the estimate can start the patient-provider dispute resolution process.
CMS tells patients to start a dispute within 120 days of getting the initial bill.
If a patient disputes a charge, CMS says the provider is asked for the estimate, the bill and any documents that explain why the bill is higher.
During the process, CMS says providers may not move the bill into collections or threaten to, and have to pause collections already under way. They can’t collect late fees on unpaid amounts or threaten retaliation against the patient.
In our view, compare each final bill with its estimate before you send it.
Before the next treatment is booked
- The information about the right to a good faith estimate is prominently displayed on your website.
- The same information is displayed in the office and where patients schedule or ask about costs.
- Whoever books a treatment asks about coverage and about claims.
- Estimates go out in writing within the rule’s deadlines.
- Each estimate carries the codes, charges, provider details and disclaimers the rule lists.
- Each estimate stays in the patient’s medical record.
RememberWhen patients don’t have or use health insurance for a treatment, CMS says providers usually have to give them a good faith estimate. They get it when they schedule care at least 3 business days ahead or ask for one. The rule requires information about that right on the website, in the office and where patients schedule or ask about costs.
With our web design for cosmetic surgery clinics, we write the site in English and Spanish and build a landing page for each procedure you advertise. Each page says what the procedure includes, and the price or financing if you publish them.
Questions about the good faith estimate
Do cosmetic procedures need a good faith estimate?
They can, when the patient doesn’t have or use insurance for them. The rule covers patients with no benefits for the item or service, and patients with benefits who do not seek to have a claim submitted. CMS adds that people covered by a federal health care program, such as Medicare or Medicaid, aren’t entitled to this estimate.
Does a price on the website replace the good faith estimate?
HHS says no. Asked about hospitals that offer a set price, it says an estimate is still required, because the actual billed charges may not reflect the set price. The estimate is also what a patient needs to dispute a bill at least $400 above it.
Do walk-in or same-day treatments need an estimate?
Not unless the patient asks, according to CMS’s fact sheet. It says an estimate isn’t required for walk-in appointments or care scheduled 1 or 2 business days ahead. Any discussion or question about the potential costs counts as a request, and the estimate is then due within 3 business days.
Can the clinic send the estimate by email or through the patient portal?
Yes. HHS says the estimate goes in writing, on paper or electronically, as the patient asks, and it gives the patient portal and email as examples. An electronic estimate has to be one the patient can save and print.
What happens if a good faith estimate has a mistake?
The rule says a provider doesn’t fail to comply solely because of an error or omission made in good faith and with reasonable due diligence. That holds provided that it corrects the information as soon as practicable. If care comes before the fix, a bill substantially above the estimate can still go to dispute resolution.
Sources
All read on November 10, 2026. The rule, on eCFR: § 149.610 Requirements for provision of good faith estimates of expected charges for uninsured (or self-pay) individuals. From CMS: Know your medical bill rights when not using insurance and Providers: payment resolution with patients. CMS guidance, in PDF: FAQs about Consolidated Appropriations Act, 2021 Implementation - Good Faith Estimates (GFEs) for Uninsured (or Self-Pay) Individuals - Part 1. A fact sheet: What is Considered “Health Insurance”? Determining When Uninsured (or Self-Pay) Good Faith Estimate Rules Apply. The model notice: Standard Notice: “Right to Receive a Good Faith Estimate of Expected Charges” Under the No Surprises Act. From the CFPB: What should I know about medical credit cards and payment plans for medical bills?