# Therapy Cancellation Policy: Template and Rules

> A therapy cancellation policy template to adapt, and the rules on charging for missed sessions: self-pay, insurance, Medicare, Medicaid, Headway and Grow.

*Source: https://fillthelobby.com/blog/therapy-cancellation-policy*

## Therapy cancellation policy: a template and the rules behind it

A therapy cancellation policy sets a notice window, defines a late cancellation and a no-show, states the fee and how it is collected, and lists exceptions. Self-pay clients can generally be charged under a written policy they agreed to. Medicare allows a fee applied equally to all patients; state Medicaid agencies we checked say no. Fill The Lobby is a marketing agency: this is a summary, not legal advice.

By [Ghazanfar Idrees](https://fillthelobby.com/about#ghazanfar-idrees), Co-founder & CEO · Updated 8 October 2026 · 15 min read

A therapy cancellation policy is the written agreement that says what happens when a client cancels late or doesn't turn up: how much notice you need, what you charge, how you collect it, and when you waive it. Most templates stop there. The harder question is whether you can charge at all, and that depends on who pays for the session.

This guide gives you a template to adapt, then the rules payer by payer: self-pay, commercial insurance, Medicare, Medicaid, and platforms like Headway and Grow. Every rule below was checked against the source on 8 October 2026. Fill The Lobby is a marketing agency, not a compliance adviser, so treat this as a summary, not legal advice, and have a healthcare attorney review your final version.

## What a therapy cancellation policy must cover

A policy that holds up answers five questions before the first session, in writing:

1. The notice window. How far ahead a client must cancel or reschedule to avoid a fee, for example 24 or 48 hours.
2. Late cancellation vs no-show. A [late cancellation](https://fillthelobby.com/glossary#late-cancellation) is a cancellation inside the window. A no-show is a session missed without notice. Define both, including how late a client can be before the session counts as missed.
3. The fee. The amount for each, that it is charged to the client directly, and that it is never billed to insurance.
4. Exceptions. Emergencies, sudden illness, and anything else you will waive the fee for, written down so it applies the same way to everyone.
5. How to cancel. The channels that count (portal, phone, email or text) and the hours they're watched.

Then add how you collect the fee, what happens after repeated missed sessions, and how much notice you give before changing the policy. The [no-show fee](https://fillthelobby.com/glossary#no-show-fee) itself is only one line of it.

## Therapy cancellation policy template

This is a template to adapt, not a finished policy. Replace everything in brackets, delete the lines that don't apply to your practice, and have a healthcare attorney check it against your state's law, your licensing board's rules and your payer contracts before you use it.

Template: cancellation and missed session policy

[Practice name] · Cancellation and missed session policy · Effective [date]

Your session time is reserved for you. If you can't make it, please tell us at least [24 / 48] hours before your session starts, so we can offer the time to someone else.

How to cancel or reschedule: [client portal link] · [phone, with the hours it's answered] · [email]. A cancellation counts from the time we receive it. [Texts to a personal number don't count.]

Late cancellation: a cancellation or reschedule with less than [24 / 48] hours' notice. Fee: [$].

Missed session (no-show): a session you don't attend without notice. For video sessions, not joining within [15] minutes of the start time counts as a missed session. Fee: [$].

Insurance: these fees are not billed to your insurance plan, because no session took place. You pay them directly. [If you see Medicaid clients: These fees do not apply to sessions covered by Medicaid.] [If you see Medicare clients: Clients with Medicare are charged the same fees, under the same policy, as clients without it.]

How the fee is paid: [the card you authorized at intake is charged / an invoice is sent] [timing, e.g. "on the next business day"]. We will tell you before any fee is charged, and you'll receive a receipt.

Exceptions: we waive the fee for [emergencies, sudden illness, severe weather, a session we cancel or move ourselves, your first session]. If something comes up, contact us as soon as you can.

Repeated missed sessions: after [number] late cancellations or missed sessions in [period], we'll talk with you about whether a different time or schedule would work better.

If we cancel: if we need to cancel with less than [24 / 48] hours' notice, there is no charge to you and we'll offer you the next available time.

Changes: we'll give you at least [30] days' written notice before changing this policy or its fees.

I have read and agree to this policy. Client name: [ ] · Signature: [ ] · Date: [ ]

Your [booking page](https://fillthelobby.com/services/booking-pages) needs a short version where people choose a time, linking to the full policy:

Template: short version for the booking page

Need to cancel? Please give us at least [24 / 48] hours' notice through [portal or phone]. Sessions canceled with less notice, or missed, are charged [$] [, except sessions covered by Medicaid]. These fees aren't billed to insurance. [Read the full policy.]

## Can you charge for missed sessions? By payer

The short answers, as checked on 8 October 2026. The detail and the sources follow.

| Who pays for the session | Can you charge the client a fee? | What decides it |
| --- | --- | --- |
| Self-pay client | Generally yes, under a policy they agreed to in advance | Your written policy, your state's law and your board's rules |
| Commercial insurance | Depends on the plan; never billed to the plan | Your contract with the plan and its provider manual |
| Medicare | Yes, if the same policy and amount apply to all patients; never billed to Medicare | CMS Medicare Claims Processing Manual, chapter 1, section 30.3.13 |
| Medicaid | Generally no, according to the state Medicaid agencies we checked | Your state Medicaid agency and any Medicaid managed care contract |
| Headway or Grow | Yes, within the platform's limits and the plan's rules | The platform's help center and payer list |

### Self-pay clients

No insurer or public program is involved, so the questions are what the client agreed to in writing, and what your state's law and your licensing board's rules allow. Some boards write the disclosure into regulation: Pennsylvania's rules for licensed professional counselors, [49 Pa. Code 49.77](https://www.pacodeandbulletin.gov/Display/pacode?file=/secure/pacode/data/049/chapter49/s49.77.html), require them to disclose charges for canceled or missed appointments before the therapeutic relationship starts, and to give reasonable notice of any change in fees once services have begun. Check your own board's rules.

Self-pay and uninsured clients are also entitled to a [good faith estimate](https://fillthelobby.com/blog/good-faith-estimate) of expected charges for the services you schedule, under [45 CFR 149.610](https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-B/part-149/subpart-G/section-149.610). The regulation doesn't mention cancellation or missed-session fees. Give clients the policy alongside the estimate and on your fees page, and ask your attorney whether your estimate should refer to it.

### Commercial insurance

There are two separate questions: can you bill the plan, and can you charge the client.

- The plan: no. A missed session isn't a service delivered. [Headway](https://help.headway.co/hc/en-us/articles/4428462506388-Cancellations-and-rescheduling) tells clients cancellation fees are never covered by insurance because a session did not take place. Billing a missed session as if it happened would misreport the service; the APA, AAMFT and Pennsylvania rules cited in this guide all require accurate reports to payers.
- The client: it depends on your contract. Some plans bar the fee, some cap it and some set it. Grow's [provider help center](https://help.growtherapy.com/en/articles/5131686-charge-for-a-no-show-or-late-cancellation) shows how much they vary: on Grow, providers can't charge Kaiser Permanente Northern California clients a no-show or late cancellation fee, Magellan caps a no-show fee at $90, and certain Cigna clients whose claims are processed through Evernorth Behavioral Care Group must be charged a $100 no-show fee, of which the provider receives $85.

Those are the terms on Grow. Your own contract with the same plan may say something different, so read your provider agreement and the plan's provider manual, or ask provider relations in writing, before you charge an insured client.

### Medicare

CMS allows it, as long as Medicare patients are treated the same as everyone else. The [Medicare Claims Processing Manual](https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c01.pdf) (Pub. 100-04, chapter 1, section 30.3.13) says physicians and suppliers may charge Medicare beneficiaries for missed appointments provided they don't discriminate against them, meaning they also charge non-Medicare patients. It calls the charge a charge for a missed business opportunity, not for a service.

- Same policy for everyone. The missed appointment policy has to apply equally to Medicare and non-Medicare patients.
- Same amount for everyone. What you charge a Medicare patient has to be the same as what you charge others.
- Never billed to Medicare. The manual says Medicare makes no payment for missed appointment fees, and the charges should not be billed to Medicare.

That is why the template's Medicare line says clients with Medicare pay the same fees, under the same policy, as clients without it. If you waive fees, waive them by written criteria that apply to everyone. If a client is in a Medicare Advantage plan, check that plan's contract as well.

### Medicaid

No CMS regulation addresses this directly, according to NC Medicaid, so this section reports what state Medicaid agencies say. The rule that applies to you is your own state's. The two we checked both say no:

- Colorado. Health First Colorado's [policy statement](https://hcpf.colorado.gov/policy-statement-charging-members-for-missed-appointments) says federal and state policies prohibit charging Medicaid members for missed or canceled appointments, and that providers can't ask members to sign forms accepting liability for them. It says CMS has consistently advised this, because missed appointments are not a distinct reimbursable Medicaid service but part of providers' overall cost of doing business, and that CMS reconfirmed it in 2015. It adds that members with Medicare or commercial insurance as the primary payer may be charged in some circumstances.
- North Carolina. NC Medicaid's [provider billing guidance](https://medicaid.ncdhhs.gov/providers-billing-missed-appt/open) (PDF) says providers may not bill Medicaid beneficiaries for missed appointments, quoting the same CMS reasoning. It notes that no CMS regulation addresses the question directly, and lists two CMS sub-regulatory letters, from 1994 and 2006, among its authorities.

The federal regulation Colorado cites, [42 CFR 447.15](https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-447/subpart-A/section-447.15), requires state Medicaid programs to limit participation to providers who accept the agency's payment, plus any required cost-sharing, as payment in full. Grow bars no-show and late cancellation fees for all Medicaid plans on its platform. If you see Medicaid clients, check your own state Medicaid agency's billing manual and any Medicaid managed care contract before your policy applies to them.

### Headway, Grow and other platforms

If you see clients through an insurance platform, its rules sit on top of the plan's. Here is what the two we checked say, as of 8 October 2026. Our [comparison of Grow Therapy, Headway and Alma](https://fillthelobby.com/blog/grow-therapy-vs-headway) covers the rest of how they work.

- Headway. Its [cancellations article](https://help.headway.co/hc/en-us/articles/4428462506388-Cancellations-and-rescheduling) says each provider sets their own cancellation policy. You choose a 24-hour or 48-hour window and a fee in whole dollars of no more than $200. A fee is charged only when you mark the session "client did not show" or "client canceled session", and it is paid in full to you. Headway says you can't charge Kaiser Permanente Northern California clients a cancellation fee, [on or off the platform](https://help.headway.co/hc/en-us/articles/23697087897108-Working-with-Medicare-Advantage-on-Headway), and the same applies to [Anthem EAP clients](https://help.headway.co/hc/en-us/articles/7473561009428-Seeing-a-client-with-Employee-Assistance-Program-EAP-benefits-on-Headway).
- Grow Therapy. Its [provider article](https://help.growtherapy.com/en/articles/5131686-charge-for-a-no-show-or-late-cancellation) treats a cancellation with less than 24 hours' notice as late, and a client who misses a session or is 15 minutes or more late as a no-show. You must stay in the session for the whole 15-minute grace period to collect the fee. Fees go up to $200 unless a payer caps them lower, and clients see them on your booking page before they book.

## What the ethics codes say about disclosing fees

None of these four codes sets a fee or a notice window. All four expect clients to know the financial terms early, as part of informed consent, and the AAMFT code names missed-appointment charges outright.

- APA (psychologists). Under [Standard 6.04](https://www.apa.org/ethics/code/ethics-code-2017.pdf), psychologists and clients reach an agreement on compensation and billing arrangements as early as feasible, fee practices are consistent with law, and fees aren't misrepresented. Standard 10.01(a) puts fees in informed consent to therapy. If you intend to use a collection agency, 6.04(e) says to tell the person first and give them a chance to pay. Standard 6.06 requires accurate reports to payers about the service provided.
- ACA (counselors). The [2014 ACA Code of Ethics](https://www.counseling.org/docs/default-source/default-document-library/ethics/2014-aca-code-of-ethics.pdf) is still the current version while ACA revises it, according to its [ethics page](https://www.counseling.org/resources/ethics). Standard A.2.b says counselors inform clients about fees and billing arrangements, including procedures for nonpayment. A.10.c asks counselors to consider clients' financial status and locality when setting fees, and A.10.d says to include any intended use of collection agencies in informed consent.
- NASW (social workers). The [NASW Code of Ethics](https://www.socialworkers.org/About/Ethics/Code-of-Ethics/Code-of-Ethics-English/Social-Workers-Ethical-Responsibilities-to-Clients) lists relevant costs among the things clients are told for informed consent (1.03(a)). Standard 1.13(a) says fees should be fair, reasonable and commensurate with the services performed, with consideration of clients' ability to pay. Standard 1.17(c) allows ending services over an overdue balance only if the financial arrangements were made clear, the client isn't an imminent danger, and the consequences have been discussed with them.
- AAMFT (marriage and family therapists). The revised [AAMFT Code of Ethics](https://www.aamft.org/common/Uploaded%20files/Legal%20Ethics/AAMFT%20Code%20of%20Ethics.pdf), effective 1 January 2026, is the most specific. Standard 8.2 requires therapists to disclose and explain in writing, before therapy begins, all financial arrangements and fees, including charges for canceled or missed appointments, and to give reasonable notice of fee changes once services have begun. Standard 8.4 requires truthful representation of services to clients and payers.

The practical reading is the same across all four: put the policy in your intake paperwork, get it acknowledged before the first session, and don't change it without notice.

## How to communicate the policy

A fee only works if nobody is surprised by it. Put the policy everywhere a client meets your fees:

1. Intake paperwork. The full policy, with a signed or clicked acknowledgment, before the first session.
2. Your fees page. Next to your session fee and the good faith estimate notice, as text rather than an image, so a client comparing practices sees it before booking.
3. The booking page. The short version, where the client picks a time. Grow shows each provider's fees in the booking flow, and that is the place to say it.
4. The reply to an inquiry. When someone asks what sessions cost, send the policy with the price, so the first conversation about money is the complete one. That reply, and the ones after it, are what our [patient follow-up](https://fillthelobby.com/services/patient-follow-up) work covers.
5. Appointment reminders. Repeat the window: "Need to cancel? Please let us know by [time]." Headway tells clients they can find their therapist's fees and cancellation window in their session reminder emails.

The policy is the backstop. Reminders people can act on, easy rescheduling and a waitlist do more of the work; our guide on [how to reduce patient no-shows](https://fillthelobby.com/blog/reduce-patient-no-shows) covers those.

## Card on file, telehealth sessions, and when to waive

### Card on file

Chasing a fee by invoice costs the front desk time and costs the practice goodwill. A card on file makes the fee collectable, which is why Headway asks providers to keep clients' payment information up to date so cancellation fees are paid promptly. If you keep one:

- get written authorization at intake that says when the card will be charged and for what;
- tell the client before you charge a fee, and send a receipt;
- keep card details in your payment system, not in session notes or email.

### Telehealth sessions

Video sessions need their own definitions, because "didn't arrive" is less obvious on a screen. Decide how long you wait before a session counts as missed, and stay in the session that long. Grow uses 15 minutes. Its client FAQ says joining only to say you can't stay still counts as a no-show, but its provider article says not to charge a no-show fee if the client joins within the grace period, even briefly, so check with Grow before charging in that case. Decide in advance what happens when the link fails on your side; the fair answer is no fee.

### When to waive the fee

- Emergencies and sudden illness. Name them in the policy so the waiver isn't a negotiation.
- The first session. Grow suggests providers consider forgiving or reducing the fee for a first-session no-show, because some clients feel apprehension and anxiety as the first session approaches.
- When a missed session means something clinical. A check-in from the clinician may be the right response before any fee. Leave room for that judgment.
- When the fee becomes the problem. NASW and ACA both ask clinicians to consider clients' ability to pay. A client who keeps missing sessions may need a different time, a different frequency, or a conversation, rather than a growing balance.

Whatever you waive, write the criteria down and apply them to everyone. Waiving for some clients and not others is where complaints start, and for Medicare patients the same policy has to apply to all.

We build the pages where your fees and policy live, and run the follow-up on inquiries that haven't booked yet, tested first on the two clinical platforms our founders own. See [therapy practice marketing](https://fillthelobby.com/therapy-practice-marketing), or start with the 30-day [Proof Pilot](https://fillthelobby.com/pilot).

## Sources

- [CMS — Medicare Claims Processing Manual (Pub. 100-04), Chapter 1, General Billing Requirements, section 30.3.13, Charges for Missed Appointments (PDF)](https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c01.pdf), checked 8 October 2026
- [eCFR — 42 CFR 447.15, Acceptance of State payment as payment in full](https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-447/subpart-A/section-447.15), checked 8 October 2026
- [Colorado Department of Health Care Policy and Financing — Policy statement: charging members for missed appointments](https://hcpf.colorado.gov/policy-statement-charging-members-for-missed-appointments), checked 8 October 2026
- [NC Medicaid — Provider billing of Medicaid beneficiaries (PDF)](https://medicaid.ncdhhs.gov/providers-billing-missed-appt/open), checked 8 October 2026
- [eCFR — 45 CFR 149.610, Requirements for provision of good faith estimates of expected charges for uninsured (or self-pay) individuals](https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-B/part-149/subpart-G/section-149.610), checked 8 October 2026
- [Pennsylvania Code — 49 Pa. Code 49.77, Payment for services (licensed professional counselors)](https://www.pacodeandbulletin.gov/Display/pacode?file=/secure/pacode/data/049/chapter49/s49.77.html), checked 8 October 2026
- [American Psychological Association — Ethical Principles of Psychologists and Code of Conduct (PDF)](https://www.apa.org/ethics/code/ethics-code-2017.pdf), checked 8 October 2026
- [American Counseling Association — 2014 ACA Code of Ethics (PDF)](https://www.counseling.org/docs/default-source/default-document-library/ethics/2014-aca-code-of-ethics.pdf), checked 8 October 2026
- [American Counseling Association — Counseling ethics and ACA Code of Ethics resources](https://www.counseling.org/resources/ethics), checked 8 October 2026
- [NASW — Code of Ethics: social workers' ethical responsibilities to clients](https://www.socialworkers.org/About/Ethics/Code-of-Ethics/Code-of-Ethics-English/Social-Workers-Ethical-Responsibilities-to-Clients), checked 8 October 2026
- [AAMFT — Code of Ethics, effective 1 January 2026 (PDF)](https://www.aamft.org/common/Uploaded%20files/Legal%20Ethics/AAMFT%20Code%20of%20Ethics.pdf), checked 8 October 2026
- [Headway Help — Cancellations and rescheduling](https://help.headway.co/hc/en-us/articles/4428462506388-Cancellations-and-rescheduling), checked 8 October 2026
- [Headway Help — Working with Medicare Advantage on Headway](https://help.headway.co/hc/en-us/articles/23697087897108-Working-with-Medicare-Advantage-on-Headway), checked 8 October 2026
- [Headway Help — Seeing a client with Employee Assistance Program (EAP) benefits on Headway](https://help.headway.co/hc/en-us/articles/7473561009428-Seeing-a-client-with-Employee-Assistance-Program-EAP-benefits-on-Headway), checked 8 October 2026
- [Grow Therapy Provider Help Center — Charge for a no-show or late cancellation](https://help.growtherapy.com/en/articles/5131686-charge-for-a-no-show-or-late-cancellation), checked 8 October 2026
- [Grow Therapy Client Help Center — No-show & late cancellation fees FAQ](https://help.growtherapy.com/clients/en/articles/9151813-no-show-late-cancellation-fees-faq), checked 8 October 2026

## Therapy cancellation policies: quick answers.

**Q: Can therapists charge for missed sessions?**

Usually, if the client agreed to the policy in writing before the first session and the payer allows it. Self-pay clients generally can be, under the policy they agreed to, subject to your state's law and your board's rules. Medicare allows it if the same policy and amount apply to every patient. Commercial plans vary by contract, and the state Medicaid agencies we checked say Medicaid members can't be charged. A missed session is never billed to the insurer as a session (checked 8 October 2026).

**Q: Can you charge a Medicaid patient a no-show fee?**

Generally no, according to the state Medicaid agencies we checked. Colorado's and North Carolina's Medicaid agencies both say providers may not charge Medicaid members for missed appointments, citing CMS's position that a missed appointment is not a distinct reimbursable Medicaid service but part of the cost of doing business. Grow bars the fees for all Medicaid plans. Check your own state Medicaid agency and any Medicaid managed care contract (checked 8 October 2026).

**Q: Can you charge Medicare patients for missed appointments?**

Yes, according to CMS's Medicare Claims Processing Manual, chapter 1, section 30.3.13, provided your missed appointment policy applies equally to all patients and the amount is the same for Medicare and non-Medicare patients. Medicare pays nothing toward the fee, and it should not be billed to Medicare (checked 8 October 2026).

**Q: Is 24 hours enough notice for a therapy cancellation policy?**

No law or ethics code we checked sets the window, so you choose it. Headway lets providers pick 24 or 48 hours, and Grow treats a cancellation with less than 24 hours' notice as late. Pick the window that gives you time to offer the slot to someone else, state it in writing before the first session, and apply it to everyone.

**Q: Should a therapist keep a card on file?**

It makes a late cancellation or no-show fee collectable without chasing an invoice. If you keep one, get written authorization at intake saying when the card will be charged and for what, tell the client before you charge it, send a receipt, and keep your waiver criteria written down so they apply to everyone.

Reviewed October 2026.

## Keep reading.

## Want your fees and policy where clients book?

## Related pages

- [Blog](https://fillthelobby.com/blog)
- [booking page](https://fillthelobby.com/services/booking-pages)
- [good faith estimate](https://fillthelobby.com/blog/good-faith-estimate)
- [comparison of Grow Therapy, Headway and Alma](https://fillthelobby.com/blog/grow-therapy-vs-headway)
- [patient follow-up](https://fillthelobby.com/services/patient-follow-up)
- [how to reduce patient no-shows](https://fillthelobby.com/blog/reduce-patient-no-shows)
- [therapy practice marketing](https://fillthelobby.com/therapy-practice-marketing)
- [Proof Pilot](https://fillthelobby.com/pilot)
- [How to reduce patient no-shows](https://fillthelobby.com/blog/reduce-patient-no-shows)
- [Good faith estimates for private practices](https://fillthelobby.com/blog/good-faith-estimate)
- [Google Ads for therapists: setup, rules and budget](https://fillthelobby.com/blog/google-ads-for-therapists)
- [How to start a private practice: a step-by-step checklist for therapists and counselors](https://fillthelobby.com/blog/how-to-start-a-private-practice)