Disclaimer: Insurance administration and dental billing recommendations, as well as interpretations of the CDT codes, represent the opinions of our experts. For the latest CDT codes and official interpretations, contact the American Dental Association or visit ADA.org. You are responsible for your own use of the CDT Codes, insurance administration, and dental billing.

Demystifying Good Faith Estimates: What Every Dental Practice Should Know 

If you work in a dental practice, you’ve probably heard chatter about Good Faith Estimates (GFEs) and wondered: “Does this actually apply to our office?” In February 2023, the Centers for Medicare & Medicaid Services (CMS) set the record straight in an update to the ADA.

The final word? Dental offices are required to provide GFEs to uninsured and self-pay patients. 

And let’s face it – no one likes billing drama. Not the patient sitting in the chair or the front-desk coordinator explaining a surprise charge at checkout. Understanding GFEs isn’t about dodging compliance penalties but building financial trust and keeping your practice running smoothly.

The No Surprises Act (NSA) went into effect in January 2022.

So what does the No Surprises Act ban? To understand GFEs, it helps to look at the broader intent of this law. In July 2021, the U.S. Departments of Health and Human Services, Labor, Treasury, and the Office of Personnel Management issued an interim final rule (“Requirements Related to Surprise Billing; Part I”) to restrict excessive out-of-pocket costs and balance billing. Specifically, the rule:

• Bans surprise billing for emergency services, treating them on an in-network basis without prior authorization.
• Bans high out-of-network cost-sharing for emergency and non-emergency care.
• Bans out-of-network charges for ancillary care at in-network facilities.
• Bans out-of-network charges without advance notice, requiring plain-language consumer consent before billing higher rates.

Where applicable, out-of-network rates are determined via specified state laws, All-Payor Model Agreements, mutual agreements between plans and providers, or an Independent Dispute Resolution (IDR) entity.

Under federal guidance, a GFE must be provided whenever care is scheduled for, or directly requested by, an uninsured or self-pay individual.

If a patient is enrolled in a group or individual health plan, your front office must ask whether they intend to submit a claim for the services. If the patient does not intend to file a claim, they are classified as self-pay for GFE purposes.

Exclusions: The NSA requirements do not apply to individuals enrolled in government programs like Medicare, Medicaid, TRICARE, Veterans Affairs (VA) Health Care, or the Indian Health Service, as these programs maintain separate billing protections.

There are delivery timelines to be aware of to stay compliant.

Timing is critical when issuing written GFEs, and mandatory deadlines depend on when an appointment is scheduled or requested.

If a service is scheduled three to nine business days in advance, your office must deliver the GFE within one business day of scheduling. If the procedure is scheduled 10 or more business days out, you have three business days from the scheduling date to deliver it. Likewise, if an uninsured or self-pay patient submits a direct request for an estimate, you must provide it within three business days.

There are scenarios when GFEs are not required, such as for emergency services, procedures scheduled less than three days in advance, or unexpected clinical situations during active treatment. If treatment needs change mid-procedure, best practice dictates pausing care to discuss the updated plan, risks, alternatives, and fees. Obtain a signed consent and fee acknowledgment from the patient, or temporize and reappoint them if they need time to decide.

There are certain required elements to ensure a properly structured GFE.

Every GFE must be issued in writing and include, but is not limited to, the following specifics:

• Patient & Provider Info: Patient name/DOB, treating provider name/title, facility legal business name, physical service address, NPI, and Tax Identification Number (TIN).
• Timestamps: Dates and times the GFE was requested and sent.
• Itemized Services & CDT Coding: Line items with current CDT codes, tooth numbers or oral cavity areas, ICD-10-CM diagnosis codes, and full practice fees (plus any discounts).
• Mandatory Disclaimers: Explicit statements that (1) fees are estimates subject to change; (2) additional unlisted treatment may be recommended; (3) the patient can trigger the Patient-Provider Dispute Resolution Process if charges exceed the estimate by $400 or more; and (4) the GFE is not a binding contract.

Ultimately, GFEs protect patients from billing surprises while fostering clear financial trust. 

Healthcare facilities must inform self-pay patients of their right to a GFE in writing. Clearly display a notice on your practice website, inside the office, and anywhere fee or scheduling questions occur. By embedding these protocols into your practice management workflows, your team ensures both federal compliance and patient confidence.

To learn more about Good Faith Estimates, review our dedicated chapter in our 2026 Dental Administration with Confidence publication!

Source:

Practice Booster (2026). Dental Administration with Confidence (pp. 242-244). 2025 eAssist Publishing, LLC.