Top 5 Challenges in Urgent Care Self-Pay Billing and How to Solve Them
December 22, 2025

The “self-pay” demographic is growing rapidly for urgent care centers. This group includes not only the 28 million uninsured Americans but also a rising number of functional self-pay patients, those with high-deductible health plans (HDHPs) who choose to pay out-of-pocket to avoid complex insurance hurdles.
However, billing for these patients is not as simple as “cash for service.” Strict federal regulations, particularly the No Surprises Act, have introduced significant administrative hurdles.
Here are the top 5 challenges in urgent care self-pay billing and how to solve them.
The sphere of self-pay billing is growing, yet it has special challenges. Knowing those barriers and applying effective strategies will ensure you are in compliance, increase collections, and keep patients satisfied.
Every uninsured or self-pay patient is required to be provided with a Good Faith Estimate (GFE) prior to the services beginning, as of January 1, 2022.
There are a lot of walk-ins in the urgent-care centers. It is difficult to make a detailed, itemized GFE in real time. Providers should provide the GFE within three business days of a request or scheduled appointment.
Patients may invoke the PPDR process in case the final bill is more than the GFE by $400 or above.
Emergency care is unpredictable. Even a mere cough might result in X-rays, nebulizer services, or lab tests, which will bring the bill past the $400 mark. This has the potential of adding additional administrative charges and revenue loss.
The federal price-transparency regulations demand that the clinics be able to post standard charges in a machine-readable format.
Tiered pricing (e.g., Level 1: Simple, Level 2: Complex) is commonly applied in urgent-care centers. Unless the documentation is comparable to the quote given at the front desk, patients will feel betrayed, thus resulting in conflicts and delayed payments.
Insurance coding is different from self-pay coding. A flat fee is represented using HCPCS S-codes in some urgent-care centers.
S-codes are not recognized by Medicare and federal programs. Using the wrong code can lead to legal liability or denial of payment.
Once the visit is done, it is significantly more difficult to collect payment. Studies indicate that collectability drops nearly 50% once patients are out of the facility.
Front-desk employees should communicate GFEs, provide payment options, and receive deposits without compromising the efficiency of patient flow.
| Challenge | Regulatory Driver | Best Practice |
| GFE Compliance | No Surprises Act | Use CMS Model Templates for all self-pay patients |
| Dispute Risk | $400 PPDR Rule | Update estimates mid-visit if new services are added |
| Price Accuracy | Price Transparency | Publish a “Menu” of common self-pay bundles online |
| Coding Errors | CMS/CPT Standards | Document E/M levels even for flat-fee visits |
| Collection Rate | Revenue Cycle Management | Implement TOS collection & Card on File for post-visit adjustments |
Self-pay billing may prove difficult. Particularly as a higher number of patients pay out-of-pocket, and the strict regulations, such as the No Surprises Act. Clinics need to make transparent cost estimates, maintain the price, and ensure the efficient collection of payments.
Partnering with experts like Tennessee Billing Solutions helps urgent care centers simplify billing, stay compliant, and improve collections.
Contact us today to learn how we can streamline your self-pay processes and make billing easier for both your staff and patients.
A GFE is a written list of estimated costs of self-pay or uninsured patients. It has to be in accordance with the No Surprises Act.
If the final bill is higher than the GFE by more than $400, patients have the right to challenge the expenses via the Patient-Provider Dispute Resolution process.
Yes. Clinics are required to make standard charges available in machine-readable format and should provide online menus for common self-pay services.
False coding may result in reimbursement or even legal action, or audit red flags. Record E/M levels even in flat-fee visits.
Utilize Time-of-Service collection, collect deposits upfront, provide payment plans, and have clear communication with patients.