Bill Higher Than Your Good Faith Estimate? How to Dispute

Written by Aptiva Health Editorial Team · Reviewed by Crystal Brake, RCM Director and Taylor Sorrels, Esq. · Editorial & review standards · How we research

If you don’t have health insurance, or you choose not to use it, providers must give you a good faith estimate before planned care. It is a written list of the charges they expect.

If the bill ends up much higher than the estimate, federal law gives you a way to dispute it. The process is called patient-provider dispute resolution. An independent reviewer looks at the bill and decides what you should pay. This guide explains who qualifies, the deadline, the fee, and how to start. It is part of the Coverage & Appeals Center.

What a good faith estimate is

A good faith estimate lists the expected charges for your care, including facility fees and hospital fees (CMS: Rights when not using insurance).

• Who gets one: people who don’t have insurance, or who have it but don’t want the claim sent to their plan (45 CFR 149.610(a)). The rules call this “uninsured (or self-pay).”
• When: providers must give you one when you schedule care at least 3 business days ahead, or when you ask for one (CMS).
• How fast: within 1 business day of scheduling if the care is 3 to 9 business days away; within 3 business days of scheduling if it is 10 or more business days away; and within 3 business days of your request (45 CFR 149.610(b)).
• In writing: on paper or electronically, the way you ask for it (45 CFR 149.610).
• How to ask: ask in writing. You don’t have to use the words “good faith” (CMS).

Keep your estimate. CMS suggests you keep it in a safe place and take a picture of it with your phone. You will need it if you dispute the bill. If you lose it, the provider must give you a copy of an estimate issued in the last 6 years when you ask (45 CFR 149.610).

Can you dispute your bill?

According to CMS, you qualify if all of these are true (CMS: Dispute a medical bill):

• When you got care, you didn’t have insurance or didn’t use it to pay.
• You got care on or after January 1, 2022.
• You have a good faith estimate from the provider or facility.
• One provider or facility billed you at least $400 more than its estimate.
• Your first bill is dated within the last 120 calendar days (about 4 months).

If you used insurance, this process is not for you (CMS). See balance billing and out-of-network denials instead.

How the $400 rule works

The rule compares each provider or facility with its own estimate. The bill must be at least $400 more than the total expected charges on that provider’s estimate (45 CFR 149.620(a)).

*These are illustrative examples, not real bills.*

The deadline: 120 days

Start the dispute within 120 calendar days (about 4 months) of your first bill (CMS: Rights when not using insurance). The federal rule says your notice must be postmarked within 120 calendar days of receiving the first bill that has the higher charges (45 CFR 149.620(c)(1)).

To be safe, count from the date printed on the bill, which is the earlier date.

Use the appeal deadline calculator to count the days.

The fee: $25

• You pay a $25 administrative fee to start. It is non-refundable (CMS: Dispute a medical bill).
• If the reviewer decides in your favor, the $25 is taken off the amount you owe the provider (CMS).
• If you and the provider settle before the decision, the provider must cut your bill by at least $12.50 (half the fee) (CMS).

After HHS gets your form, it sends you a link to pay the fee online. If you mail the form, you can include a cashier’s check or money order. Do not send cash or a personal check (CMS dispute form).

How to start a dispute

1. Check that you qualify. Use the list above. The first page of the CMS form also walks you through it.
2. Gather your papers. You need a copy of the bill, a copy of the good faith estimate, and the provider’s contact information (CMS).
3. Start the dispute online. Go to the CMS bill dispute portal at nsa-idr.cms.gov/billdisputes (CMS).
4. Or use the paper form. Download the patient-provider dispute resolution form (PDF) and send it by mail or fax. Follow the instructions on the form for where to send it.
5. Pay the $25 fee. Pay online through the link HHS sends, or include a cashier’s check or money order if you mail the form.
6. Keep copies. Keep a copy or photos of the completed form (CMS dispute form). Write down the date you sent it.
7. Tell the provider. You don’t have to, but it can help to let the billing office know you started a dispute. See the sample note below.

Need help? Call 1-800-985-3059 or email FederalPPDRQuestions@cms.hhs.gov (CMS dispute form).

What the form asks for

The federal rule says your dispute must include (45 CFR 149.620(c)(2)):

• Information that identifies you and the care in question.
• A copy of the bill.
• A copy of the good faith estimate.
• The provider’s or facility’s contact information, if needed.
• The state where you got care.
• How you want to be contacted.

Your sample note to the provider

The dispute itself is started on the official CMS portal or form, not by letter. This optional note lets the provider’s billing office know a dispute is open.

[Your name]
[Your address] · [Your phone] · [Your email]

[Date]

[Provider or facility name] — Billing Office
[Address or fax from your bill]

RE: Patient-provider dispute resolution started
Patient name: [Name]
Account number: [Number]
Date(s) of service: [Date or dates]
Good faith estimate date: [Date] · Estimated total: $[Amount]
Bill date: [Date] · Billed total: $[Amount]

To the Billing Office:

I was an uninsured (or self-pay) patient for this care. Your bill is $[Amount] more than your good faith estimate.

On [date], I started a patient-provider dispute with the U.S. Department of Health and Human Services. [My dispute number is [Number], if you have one.]

While the dispute is open, please do not send this bill to collections, and please pause any late fees. If the bill is already with a collection agency, please pause collection.

I am still open to talking about a lower bill. You can reach me at [phone] or [email].

Sincerely,
[Signature]
[Printed name]

While the dispute is open

• No collections. The provider can’t move your bill into collections or threaten to (CMS). If the bill is already in collections, the provider must pause collections (CMS: Providers).
• No late fees. The provider must pause late fees on the unpaid amount until the dispute ends (45 CFR 149.620(c)(5)).
• You can still negotiate. While the dispute is happening, you can still ask the provider for a lower bill (CMS dispute form). See how to negotiate a medical bill.

What the reviewer decides

An independent reviewer (the rules call it a selected dispute resolution entity) looks at your estimate, your bill, and information from the provider. The reviewer decides how much you should pay (45 CFR 149.620(f)). Then it tells you and the provider (CMS: Providers).

• If the reviewer decides in your favor, the provider must lower your bill, and the $25 fee is taken off what you owe (CMS).
• If the reviewer finds the extra charges were for care that was needed and not planned, your bill may stay the same (CMS).

What if you can’t use this process?

• The bill is less than $400 over the estimate. You can still ask the provider to lower the bill and ask about financial help. The CMS form says the same (CMS dispute form).
• You never got an estimate but think you should have. Visit CMS’s consumer page or call 1-800-985-3059 (CMS dispute form).
• You used insurance. This process doesn’t apply. Check whether the bill is a surprise bill. See balance billing.
• You missed the 120 days. Ask the provider for an itemized bill and a lower amount. See how to get an itemized bill.

What about “IDR”? It is not for patients

You may read about independent dispute resolution (IDR) under the No Surprises Act. IDR is a different process. It settles payment disputes between providers and health plans. The rules for it apply to plans and insurers, providers, facilities, air ambulance providers, and IDR entities (CMS: IDR Operations fact sheet). You do not file it, and you don’t pay its fees.

New federal IDR rules took effect on August 3, 2026 (Federal Register, June 4, 2026). They cut the IDR administrative fee to $15 per party per dispute (CMS: IDR Operations fact sheet). That fee is paid by providers and plans. It does not change the $25 fee for a patient’s bill dispute. See out-of-network denials for more on IDR.

Common mistakes

• Throwing away the estimate. Without it, you can’t show the difference.
• Waiting too long. The 120 days start with the first bill, not a later reminder.
• Adding up different providers. The $400 rule compares each provider with its own estimate.
• Paying the full bill first. Check whether you qualify before you pay.
• Sending cash or a personal check. Use the online payment link, a cashier’s check or a money order.

Questions about an Aptiva estimate or bill?

If you are an Aptiva patient paying without insurance, ask us for a good faith estimate when you schedule. If a bill doesn’t match your estimate, contact our billing team before your deadline.

For other billing questions, start at the Coverage & Appeals Center.