Generate and deliver a Good Faith Estimate (GFE) to a self-pay patient when a service is scheduled 3 to 9 business days in advance under the No Surprises Act
When a self-pay or uninsured patient schedules an item or service, record the exact date and time of scheduling as the trigger date for GFE timing.
Determine the scheduling lead time: if the service is scheduled 3 to 9 business days in advance, the GFE must be provided no later than 1 business day after the date of scheduling (not 1 business day before the service date).
Assemble the GFE to include the expected service description, billing codes, expected charges for each provider involved in the expected care, and anticipated collection amounts from the patient.
Coordinate with any co-providers (for example, an anesthesiologist or assistant surgeon) to collect their expected charge information and include it in the primary provider's GFE as a convening provider is required to do.
Deliver the GFE in writing — by mail, electronically, or in person — and retain a copy with the delivery date documented for compliance purposes.
For services scheduled 10 or more business days in advance, the GFE must be provided within 3 business days after scheduling, not within 1 business day.
Known gotchas
The 1-business-day deadline runs from the date of scheduling, not from the service date; delivering the GFE 1 business day before the appointment satisfies the requirement only for the 10-or-more-business-day scenario, not the 3-to-9-day scenario where the clock starts at scheduling.
An updated GFE is required when the scope of services changes materially; that updated GFE must be provided at least 1 business day before the service date, which is a different timing rule than the initial GFE.
The GFE must cover all expected providers in the episode of care, not just the scheduling provider; failure to include co-provider charges is a common compliance gap.
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