Therapist & Counselor Billing Audit
Make sure every psychotherapy session is coded to the time you documented and ready for the payer audits that target 90837.
Psychotherapy codes are selected by time, which makes them easy for payers to audit: 90832 covers 16–37 minutes, 90834 covers 38–52 minutes and 90837 covers 53 minutes or more. Practices that bill 90837 for most sessions are regularly flagged by commercial payers and behavioral health administrators for record reviews and recoupments, even when the sessions were legitimately long. Our audit checks that start and stop times or total time are documented for every session, that the note supports medical necessity and ties to a current treatment plan, and that telehealth sessions carry the place-of-service code and modifier each payer requires. For group practices we also check credentialing, including Medicare enrollment for marriage and family therapists and mental health counselors, who became eligible to bill Medicare in 2024.
Audit red flags
- More than half of individual sessions billed as 90837 without documented start and stop times.
- Progress notes copied forward that do not show the intervention, the patient's response or progress toward treatment-plan goals.
- Telehealth sessions billed without the place-of-service code or modifier the payer requires (for example POS 10 or modifier 95).
- Clinicians billing under a group NPI before their individual credentialing with that payer is complete.
Audit action plan
- 1. Time & Medical Necessity Review — Sample sessions for each clinician and confirm the documented time supports the code billed and the note supports medical necessity.
- 2. 90837 Exposure Analysis — Compare each clinician's share of 90837 claims by payer to see where record requests and recoupments are most likely.
- 3. Telehealth & Credentialing Check — Verify place-of-service codes, modifiers and each clinician's payer enrollment status against the claims they are billing.
Codes reviewed
- 90837 — Psychotherapy, 60 minutes (53 minutes or more)
- 90834 — Psychotherapy, 45 minutes (38–52 minutes)
- 90791 — Psychiatric diagnostic evaluation (no medical services)
- 90846 / 90847 — Family psychotherapy without / with the patient present
Frequently asked questions
Why do payers audit 90837 so often?
It is the highest-paying individual psychotherapy code and some practices bill it for nearly every session. Payers run outlier reports to flag clinicians with high 90837 rates and then request records to confirm the documented time and medical necessity.
Do therapists have to document start and stop times?
Some payers require start and stop times; others accept total time. Documenting both is the safest way to support time-based psychotherapy codes in an audit.
Can licensed professional counselors bill Medicare?
Yes. Since January 1, 2024, marriage and family therapists and mental health counselors, including many licensed professional counselors, can enroll in and bill Medicare Part B for the diagnosis and treatment of mental illness.