All-in pricing and junk fee laws for practices

A practice lists a self-pay visit at one price, and the patient pays more at checkout because of an administrative fee, a booking fee or a card surcharge that applies to each visit. Federal regulators call this drip pricing. California, Minnesota and Virginia now have laws that require the advertised price to include each mandatory fee, and those laws are written for goods and services broadly, not for hotels and concert tickets alone. FTC staff list drip pricing among the design practices covered in our guide to dark patterns on healthcare websites.

This guide covers those all-in pricing laws as they apply to the prices a practice publishes: self-pay visits, procedure prices, packages and memberships. It does not repeat the general federal rules on price advertising, which are in our guide to advertising cash prices. For hospital-based clinics, see facility fee disclosure. For subscriptions, see membership auto-renewal rules, and for the federal estimate owed to self-pay patients, see our good faith estimate guide. If you plan to match a competitor’s price or accept their coupon, see our guide to price matching and competitor coupons. For sale prices and offer deadlines, see our guide to countdown timers and limited-time offers.

This is general information, not legal advice. Sources cited were checked on October 30, 2026: 16 CFR Part 464 (eCFR), 15 U.S.C. 45, the California Attorney General’s SB 478 FAQ on California Civil Code 1770(a)(29), Minnesota Statutes 325D.44 and Minnesota Session Laws 2024, chapter 111, Virginia Code 59.1-199, 59.1-200 and 59.1-207.45, and 45 CFR 149.610. Rules differ by state, and whether a given health service or fee falls under a state law is a question for counsel. Have a health care attorney review your price pages before they go live.

The federal fee rule does not reach medical visits

The FTC’s Rule on Unfair or Deceptive Fees, 16 CFR Part 464, was published on January 10, 2025. Section 464.2 bars a business from advertising a price of a covered good or service without clearly and conspicuously disclosing the total price, and requires the total price to be shown more prominently than other pricing information. Section 464.1 defines a covered good or service as live-event tickets or short-term lodging. A medical visit is neither, so the rule does not apply to a practice’s own services.

Two parts of the rule still matter. Section 464.4 says the rule does not supersede state laws on unfair or deceptive fees except where they are inconsistent, and a state law is not inconsistent if it gives consumers greater protection. That is where the state laws below come in. And the rule’s definition of total price is a useful model: the maximum total of all fees or charges a consumer must pay, including any mandatory ancillary good or service, with government charges, shipping charges and optional add-ons allowed to be left out.

Outside Part 464, Section 5 of the FTC Act, 15 U.S.C. 45, still prohibits deceptive acts or practices, so a price that leaves out a fee the patient cannot avoid can be deceptive under federal law even where no all-in statute applies.

California: the price shown must be the price paid

California Civil Code 1770(a)(29), added by SB 478 and in force since July 1, 2024, makes it unlawful to advertise, display or offer a price for a good or service that does not include all mandatory fees or charges, other than taxes or fees the government imposes on the transaction and postage or carriage charges reasonably and actually incurred to ship a physical good. The California Attorney General’s FAQ on the law, checked October 30, 2026, answers the questions a practice is likely to ask:

The law applies to the sale or lease of goods and services for a consumer’s personal use. It does not apply to purchases for commercial use or to certain transactions and industries covered by other pricing laws.
Disclosing the extra fee before the consumer finalizes the purchase does not meet the law. Neither does advertising a lower price with a note that more fees will be added, or a separate note that a percentage fee applies.
Fees that pay business costs, the FAQ lists security, rent, salary and employee healthcare benefits, must be included in the advertised price.
Fees for optional services or features need not be included. Fees that depend on later conduct by the consumer, the FAQ’s examples are a late return fee for rented equipment and a charge for smoking in a non-smoking hotel room, are not mandatory.
A credit card fee is generally not mandatory if the customer can avoid it by paying another way. If the business only accepts cards, the card fee is mandatory and belongs in the advertised price.
A business that does not know what it will charge at the start of a transaction should wait to display a price until it does.
A business may advertise the total price and then show a breakdown of what it includes. Charging less than the advertised price, through a discount, does not violate the law.

Whether a particular health service counts as a consumer transaction under this statute, and how it interacts with other California health care laws, is a question for California counsel. The safer reading for marketing is simple: if a fee is charged on each visit or each purchase of the advertised service, put it in the number.

Minnesota: mandatory fees and services priced by time or choice

Minnesota Statutes 325D.44, subdivision 1a, added by Minnesota Session Laws 2024, chapter 111, and effective January 1, 2025, makes it a deceptive trade practice to advertise, display or offer a price for goods or services that does not include all mandatory fees or surcharges. The statute defines a mandatory fee to include a fee or surcharge that must be paid to buy the advertised goods or services, that the consumer cannot reasonably avoid, or that a reasonable person would expect to be included in the purchase. Taxes imposed by a government entity are not mandatory fees.

Two parts of the subdivision fit practice pricing. Paragraph (e) says nothing in it prevents offering a service at a discount from the advertised price. Paragraph (g) addresses services whose total cost depends on the consumer’s selections and preferences, or on distance or time. For those, the subdivision is met if the seller clearly and conspicuously discloses the factors that determine the total price, any mandatory fees, and that the total cost may vary. A treatment priced by units, area or session length is close to that description, but read the full text with counsel before relying on it.

Subdivision 1b exempts certain motor vehicle dealer fees, businesses regulated by the Minnesota Public Utilities Commission, and real estate settlement service charges. Health care is not on that list.

Virginia: total cost before the agreement

Virginia takes a narrower approach. Virginia Code 59.1-200(A)(79) lists as a prohibited practice failing to disclose the total cost of a good or continuous service, including any mandatory fees or charges, to a consumer before entering into an agreement for its sale or provision. Virginia Code 59.1-207.45 defines a continuous service as a plan or arrangement in which a subscription or purchasing agreement continues until the consumer cancels.

For a practice, the clearest fit is a membership or subscription plan that runs until the patient cancels. The disclosure point is before the agreement, so the enrollment page and the sign-up form are where the total cost, with any enrollment or administrative fee, needs to appear. Virginia Code 59.1-199 lists exclusions from the Virginia Consumer Protection Act, and counsel should confirm none applies to your arrangement.

Other states and professional rules

This guide covers three state laws we read in full. Other states have consumer protection statutes, attorney general rules and pending bills on fees, and they change from session to session. Before you publish prices in a state, check its consumer protection statute, its attorney general’s guidance and the advertising rules of each licensing board named on the page. Board rules on fee advertising are separate from the consumer protection laws above and can add their own requirements.

Fees that turn up in practice pricing

Each item below is a fee a practice might charge. The question for each is the same: must the patient pay it to get the service you advertised?

Administrative, booking, intake or paperwork fees charged with each new patient visit. If each new patient pays it, it belongs in the new patient price.
Enrollment or activation fees on a membership. Show them with the monthly price on the plan page, and before sign-up.
Platform or technology fees on a telehealth visit. If each visit carries one, include it.
Supply, kit or lab processing fees bundled into a procedure. If the procedure cannot be done without them, they are part of its price.
Card surcharges. Under the California FAQ, a surcharge the patient can avoid by paying another way is generally not mandatory; a surcharge on a card-only service is.
Facility fees at hospital-owned locations. These raise their own federal and state rules, covered in our facility fee guide.
Missed appointment and late cancellation fees. These depend on what the patient does later, which resembles the California FAQ’s examples of contingent fees. Disclose them in your policy, as covered in our no-show policy guide.
Optional add-ons, such as an upgraded product or an extra service the patient chooses. These can stay outside the advertised price if they are truly optional.

Starting-at prices, packages and memberships

A starting-at price is the lowest amount a patient can pay. Under an all-in law, that lowest amount still has to include mandatory fees for the lowest option. Use: “Visits from [amount], including the [fee name] fee.” Avoid: “Visits from [amount] plus fees.”

A package price should be the total for the package, including any fee charged once per package. If a package is sold per session with a separate fee on the first session, show both and the total. Use: “[N] sessions, [total] total, including the [fee name] fee.” Avoid: “[amount] per session” when a first-session fee is added at booking.

A membership has two prices that matter to the patient: the recurring amount and anything charged at enrollment. Show both together on the plan page, in ads that name a price, and on the sign-up screen before the patient agrees. Use: “[amount] per month, with a one-time [amount] enrollment fee.” Avoid: a monthly price in the headline and the enrollment fee only in the terms. Our auto-renewal guide covers the separate consent and cancellation rules, and our dental membership plan guide covers plan wording.

When a service cannot be priced until the patient is assessed, the California FAQ’s advice is to wait to show a price until you know it. A range with the factors that move it, or a consultation price that is itself all-in, avoids a number the patient will not pay.

How this sits with the good faith estimate

An all-in advertised price and a federal good faith estimate are separate duties. Under 45 CFR 149.610, providers and facilities must give uninsured or self-pay individuals a good faith estimate of expected charges upon scheduling an item or service or upon request, and must inform them that the estimate is available. The rule requires that notice to be written clearly, prominently displayed and easily searchable from a public search engine on the website, and posted in the office and on site where scheduling or questions about cost occur.

The estimate covers the scheduled item or service and the items or services reasonably expected to be provided with it. A website price does not replace it. Keep the two consistent: if the advertised price includes a fee, the estimate should show it too, and a patient who compares the two should not find a fee in one and not the other. Our good faith estimate guide covers the content and timing rules.

Notes by specialty

Dental: new patient specials and membership plans are where fees appear. Put exam, cleaning and imaging fees for the offer in the offer price, and enrollment fees next to the monthly fee. See our dental membership guide.
Med spa: treatments priced per unit, area or syringe fit the Minnesota description of services priced by the consumer’s choices. Disclose the factors, any mandatory consultation or numbing fee, and that the total varies. If a consultation fee is credited toward treatment, say so plainly.
Chiropractic: a new patient offer that requires an exam or imaging at an extra charge should include it, or the offer price is not the price paid. See our guide to chiropractic new patient offers.
Integrative and direct care: memberships can carry enrollment fees and separate lab or supplement charges. Show which charges are part of membership and which are optional.
Telehealth: show the visit price with any platform or prescription processing fee each patient pays. See our telehealth marketing guide.

Illustration: one price page, before and after

This illustration is invented to show the method. It does not describe a real practice, price or result.

[Practice name] lists “Self-pay visit: [amount]” on its pricing page. At checkout, each new patient also pays a [amount] intake fee, and the practice adds a [percent] surcharge because it only takes cards. In a state with an all-in law, the advertised number is lower than what each new patient pays.

After review, the page reads: “New patient visit: [total], including intake. Return visit: [total].” The practice either includes the card cost in the price or adds a way to pay without it. The breakdown sits under the price, the membership page shows the enrollment fee next to the monthly amount, and the good faith estimate template lists the same items. The front desk script quotes the same totals.

Checklist before a price goes live

List each fee the practice charges and mark it mandatory, optional or contingent on what the patient does later.
Add each mandatory fee to the advertised price for the service it applies to.
Check card surcharges: if patients cannot pay another way, treat the surcharge as mandatory.
Rewrite starting-at prices so the lowest option includes its mandatory fees.
Show membership enrollment fees next to the recurring price, and on the sign-up screen before agreement.
For services priced by units, time or choices, list the factors, the mandatory fees and that the total varies.
Match the website, ads, price assets, emails, front desk scripts and good faith estimate template.
Check the law of each state where you advertise to patients, and each licensing board’s advertising rules.
Record who reviewed the price page and when, and recheck when fees change.

How we help

We build websites, local search, Google Ads and lead generation and AI front desk tools for independent practices and health businesses. For pricing, that means price pages that show the total a patient pays, ads and price assets that match them, and front desk scripts that quote the same numbers, with a list of each price claim for your attorney to review. Our tools are built with HIPAA in mind. We confirm in writing what a BAA covers before any patient information flows through a tool, and if it is not covered, we do not route patient information through it. We are not a healthcare provider and we do not give legal or medical advice. For the wider rules, see our healthcare marketing rules hub.

Does the FTC junk fees rule apply to medical practices?

Not directly. 16 CFR 464.1 limits the rule to live-event tickets and short-term lodging. Section 5 of the FTC Act still prohibits deceptive pricing, and 16 CFR 464.4 leaves state laws that give consumers greater protection in place.

Can we list a price and say fees may apply?

In California, no. The Attorney General’s SB 478 FAQ says advertising a lower price with a note that fees will be added does not meet Civil Code 1770(a)(29). Minnesota Statutes 325D.44, subdivision 1a, also requires the advertised price to include mandatory fees.

Do we have to include a credit card surcharge in the price?

Under the California FAQ, generally not if patients can avoid it by paying another way. If you only accept cards, the surcharge is mandatory and must be in the advertised price. Confirm the details with counsel.

Does a missed appointment fee have to be in the visit price?

The California FAQ treats fees that depend on a consumer’s later conduct as not mandatory, using examples such as late return fees. A missed appointment fee resembles those examples, but confirm with counsel and disclose the fee clearly in your policy.

How do we advertise a treatment priced by units or area?

Minnesota Statutes 325D.44, subdivision 1a(g), addresses services whose cost depends on the consumer’s choices or on time: disclose the factors that set the price, any mandatory fees, and that the total may vary. Otherwise, advertise a price for a defined option that includes its fees.

Does an all-in price replace the good faith estimate?

No. Under 45 CFR 149.610, self-pay patients are owed a good faith estimate upon scheduling or upon request, whatever your website says. Keep the advertised price and the estimate consistent.

Advertised prices and hidden fees: state all-in pricing laws for medical practices