Patient guide
Your Bill Came In $400 or More Over Your Good Faith Estimate. Here Is the Federal Dispute Process, in the Government's Own Words.
If you are uninsured or paying cash and your final bill is at least $400 more than your Good Faith Estimate, federal law gives you 120 days to challenge it. This guide walks through the Patient-Provider Dispute Resolution process under 45 CFR 149.620: the $25 fee, the 30-business-day decision, and how to file.
Reviewed by the CheckMyDenial team, patient billing and appeals. Last reviewed: September 4, 2026.
Short answer: if you are uninsured or paying cash, a provider has to give you a Good Faith Estimate before treatment under 45 CFR 149.610. If the final bill for the same items and services comes in at least $400 more than that estimate, you can dispute it under 45 CFR 149.620. You have 120 calendar days from the date of the bill to start the process, it costs $25 to file, and an independent reviewer has up to 30 business days to decide what you actually owe. The provider has to pause collections while your dispute is open.
This process has nothing to do with insurance denials. It exists for the specific situation where you paid cash or went without insurance, got a written estimate, and the bill did not match it. If you have insurance and a claim was denied or you were balance-billed by an out-of-network provider in an emergency, a different set of protections applies, and this is not that page.
What is a Good Faith Estimate, and who has to give me one?
A Good Faith Estimate is a written breakdown of expected charges that a provider or facility must give an uninsured or self-pay patient, either when you schedule an item or service or when you ask for one, under 45 CFR 149.610. It has to list the expected charges for the primary service and for any other items or services reasonably expected to be provided in conjunction with it, itemized by provider or facility. You are entitled to it whether or not you actually have health coverage, as long as you are not billing that coverage for the visit.
Keep it. The estimate is the document the dispute process measures your final bill against, and CMS advises keeping a copy or a photo of it for exactly that reason.
How much does the bill have to exceed the estimate?
| Question | Answer |
|---|---|
| Who can file | Uninsured or self-pay patients only |
| Threshold to qualify | Bill is at least $400 more than the Good Faith Estimate, for the same provider/facility and items |
| Deadline to start | 120 calendar days from the date on the bill |
| Filing fee | $25, refunded to you if the decision is in your favor |
| Decision timeframe | Up to 30 business days once the entity has the needed information |
| Effect on collections | Provider must pause or hold off on collections while the dispute is open |
| Governing regulation | 45 CFR 149.620 |
The $400 line is not a suggestion or a rule of thumb the government picked at random for this guide. It is the figure CMS uses in its own consumer guidance to define when a bill is "substantially in excess" of the estimate, the trigger the regulation requires before the dispute process is available.
How do I actually start a dispute?
You initiate the Patient-Provider Dispute Resolution process within 120 calendar days of the date on the bill showing the higher charge, not the date you received care. CMS's consumer page at cms.gov/nosurprises/consumers walks through where to submit the request and what to attach: your Good Faith Estimate and the bill itself, side by side. The $25 administrative fee is due when you file. If the dispute resolution entity later rules that you owe less than the bill charged, that fee comes back to you out of the payment determination.
What happens to the bill while the dispute is pending?
The provider cannot move the account into collections, and cannot threaten to, once your dispute has started. CMS states this directly in its guidance to providers: if the bill is already with a collections agency, the provider has to pause that activity. This is one of the more useful protections in the process, because it means disputing does not put your credit at risk while the review is underway.
What does the dispute resolution entity actually decide?
A Selected Dispute Resolution entity, independent of both you and the provider, compares the Good Faith Estimate to the actual bill, item by item, and issues a binding payment determination. It has up to 30 business days to do that once it has received the provider's Good Faith Estimate, the bill, and any supporting documentation explaining the difference. You and the provider can also settle directly at any point before the decision; if you do, the provider has to notify the dispute resolution entity of the settlement, and CMS's guidance puts that notice window at a few business days after you reach agreement.
Does this apply if I have insurance and got balance-billed?
No, and this is the distinction worth getting right before you file anything. The Patient-Provider Dispute Resolution process under 45 CFR 149.620 is built for uninsured and self-pay patients comparing a bill to their own Good Faith Estimate. If you have coverage and you were billed by an out-of-network emergency provider, or an out-of-network provider at an in-network facility, the No Surprises Act's separate balance-billing protections and the Federal Independent Dispute Resolution process between your plan and the provider apply instead, and you generally are not part of that negotiation at all. If your issue is a denied claim rather than a bill that outran an estimate, your path is your plan's internal appeal, and for non-grandfathered plans, external review under 45 CFR 147.136.
A note on who we are
CheckMyDenial helps patients read and appeal insurance denials and billing disputes. We are related to a company that does medical-dental billing and reimbursement for patients and practices, and if you ever move from reading to having someone handle a claim or dispute for you, that relationship and any fee are disclosed before anything is paid. This page is free, it does not require anything from you, and it will stay that way.
Where this comes from
Everything above is drawn from the regulations themselves, 45 CFR 149.610 and 149.620, created under the No Surprises Act provisions of the Consolidated Appropriations Act, 2021, and from CMS's own consumer and provider guidance on the Good Faith Estimate and Patient-Provider Dispute Resolution process, which is where the $400 threshold, the 120-day filing window, the $25 fee, and the 30-business-day decision timeframe are stated directly. Links are listed at the end of this page. If you find something here that is out of date, tell us and we will fix it and change the date at the top.
Questions people ask
What is the Patient-Provider Dispute Resolution process?
It is a federal process, created under the No Surprises Act and set out at 45 CFR 149.620, that lets an uninsured or self-pay patient challenge a bill that came in substantially higher than the Good Faith Estimate the provider gave before treatment. An independent Selected Dispute Resolution entity reviews the estimate and the bill and decides what you actually owe.
Who can use the Patient-Provider Dispute Resolution process?
Only uninsured or self-pay patients, meaning you did not use health insurance to pay for the item or service, whether or not you have a health plan. If you billed your insurance and are disputing a denial or an out-of-network charge, this is not your process. That runs through your plan's internal appeal, and for many plans an external review under 45 CFR 147.136.
How much does my bill have to exceed the estimate before I can dispute it?
At least $400 above the total expected charges listed on the Good Faith Estimate, for the same provider or facility and the same items or services. CMS treats that gap as 'substantially in excess' of the estimate under 45 CFR 149.620. A bill that runs $50 or $200 over the estimate does not qualify for this process, though you can still ask the billing office to explain the difference.
How long do I have to start a dispute?
120 calendar days from the date on the first bill that shows the higher charge. That clock starts on the bill, not on the date of service and not on a later statement. If you miss the 120 days, the Patient-Provider Dispute Resolution process is no longer available to you for that bill.
What does it cost to file, and do I get it back?
The administrative fee is $25. If the dispute resolution entity decides you owe less than the billed amount, the $25 is credited back to you out of the payment determination. If you and the provider settle the dispute yourselves before a decision, you can agree to split the fee.
Can the provider send my bill to collections while the dispute is pending?
No. Once you have initiated the process, the provider is required to hold off on collections activity, and if the bill is already in collections, that has to pause. CMS states this directly in its guidance to providers on payment resolution with patients.
How long does the dispute resolution entity take to decide?
Up to 30 business days from when it has the information it needs from the provider, which includes the original Good Faith Estimate and the actual bill. The entity compares the two, item by item, and issues a payment determination that is binding on both sides.
Sources
- 45 CFR 149.610, requirements for Good Faith Estimates for uninsured or self-pay individuals (eCFR)
- 45 CFR 149.620, requirements for the patient-provider dispute resolution process (eCFR)
- CMS, Medical bill rights: payment disagreements (consumer page, the $400 threshold and how to start a dispute)
- CMS, Providers: what to expect when a patient starts payment dispute resolution (collections hold, settlement notice)
- CMS, No Surprises Act Good Faith Estimate and Patient-Provider Dispute Resolution requirements (slide deck: fee, deadline, decision timeframe)
- 45 CFR 147.136, external review of adverse benefit determinations (the process for insured patients, referenced for contrast)