Mental health practices lose an estimated $30,000 to $50,000 every year to preventable claim denials. CPT code 90837 sits at the center of more billing disputes than any other psychotherapy code, according to industry analysis of behavioral health denial patterns.
The problem isn’t that providers don’t understand the code. It’s that the rules around it, the documentation expectations, the payer-specific quirks, and the audit triggers, keep shifting. And when something slips, it doesn’t just cost you one claim. It creates a pattern that bleeds revenue for months before anyone catches it.
At One O Seven RCM, we handle end-to-end medical billing for behavioral health practices nationwide. This guide is built from real-world claims data and denial pattern analysis, not textbook definitions. Every recommendation here comes from what we’ve seen actually work across thousands of psychotherapy claims.
Here’s what we cover: the 53-minute rule, ICD-10 code pairings, payer-specific reimbursement tables, telehealth modifiers, documentation frameworks that hold up under audit, five real-world billing scenarios, and a step-by-step denial appeal process. Whether you’re a solo LCSW or managing a 20-provider group practice, this is the only CPT code 90837 resource you’ll need.
What Is CPT Code 90837? Definition, Description & Scope
CPT code 90837 is defined by the American Medical Association (AMA) as “Psychotherapy, 60 minutes with patient.” It represents individual, face-to-face psychotherapy sessions lasting 53 minutes or longer, making it the highest-level standalone psychotherapy code available. The code falls under the Psychiatry/Psychotherapy section of the CPT manual (codes 90785 to 90899).
That’s the official definition. Here’s what it means in practice: if you’re providing individual therapy and the session hits 53 minutes of face-to-face time, this is your code. Anything under 53 minutes drops to 90834. There’s no gray area.
What 90837 covers:
- Individual (one-on-one) psychotherapy
- Face-to-face therapeutic interaction
- Insight-oriented, behavior-modifying, and supportive interventions
- Evidence-based therapeutic modalities
What 90837 does NOT cover:
- Psychiatric medication management: use E/M codes like 99213 or 99214
- Group therapy: use 90853
- Family therapy without the patient present: use 90846
- Family therapy with the patient present: use 90847
- Psychological testing: use 96130 to 96139
- Administrative tasks, chart review, or documentation time
- Phone calls, emails, patient portal messages, or care coordination
- Peer support services
Every exclusion above has a specific code that belongs to it. Billing 90837 for any of these services isn’t just incorrect. It’s a compliance risk.
Therapy modalities billable under 90837:
- Cognitive Behavioral Therapy (CBT)
- Dialectical Behavior Therapy (DBT)
- Eye Movement Desensitization and Reprocessing (EMDR)
- Psychodynamic therapy
- Trauma-Focused CBT (TF-CBT)
- Motivational Interviewing (MI)
- Acceptance and Commitment Therapy (ACT)
- Interpersonal Therapy (IPT)
- Exposure and Response Prevention (ERP)
- Solution-Focused Brief Therapy (SFBT)
The modality doesn’t determine the code. The time does. You can provide CBT, EMDR, or DBT under 90837 as long as you hit the 53-minute threshold and document accordingly.
Who Can Bill CPT Code 90837?
Not every licensed mental health professional can bill this code to every payer. Eligibility depends on your license type, state scope of practice, and whether you’re credentialed with the specific insurer.
Eligible provider types:
- Psychiatrists (MD/DO)
- Psychologists (PhD/PsyD)
- Licensed Clinical Social Workers (LCSW)
- Licensed Professional Counselors (LPC/LPCC)
- Licensed Marriage and Family Therapists (LMFT)
- Psychiatric-Mental Health Nurse Practitioners (PMHNP)
- Licensed Clinical Professional Counselors (LCPC)
- Licensed Clinical Alcohol and Drug Counselors (LCADC), accepted by some states and payers
- Clinical Nurse Specialists (CNS) in psychiatric specialty
State scope-of-practice laws determine which provider types can deliver psychotherapy independently. Some states restrict certain license types from billing without supervision. Verify your state’s rules before assuming you can bill 90837 under your own NPI.
Credentialing Requirements Before You Can Bill
Here’s where a lot of new providers lose revenue before they even start: having a license doesn’t mean you can bill insurance. There’s a gap between being licensed and being able to submit claims, and it’s bigger than most people realize.
Before you can bill 90837 to any payer, you need four things in place:
- Active state license in the state where services are rendered, not where your office is located
- Medicare enrollment through PECOS if you’re billing Medicare
- Credentialing and paneling with each commercial payer you want to bill
- Correct NPI and taxonomy code on file: Taxonomy 101Y for psychologists, 1041C for clinical social workers, and so on
Credentialing takes 60 to 120 days with most payers. If you start seeing patients before paneling is complete, you’re providing services you can’t bill for. That’s not a minor inconvenience. For a full-time therapist, that’s potentially $15,000 to $30,000 in unbillable sessions.
If you need help with credentialing and contracting, One O Seven RCM manages the entire enrollment and paneling process for behavioral health providers.
90837 Time Range: The 53-Minute Rule Explained
The 90837 time range requires a minimum of 53 minutes of face-to-face psychotherapy. Despite being labeled a “60-minute” code, the billable threshold starts at 53 minutes per the AMA’s time-based coding midpoint rules. Sessions lasting 52 minutes or less must be billed under CPT 90834. Billing 90837 for a sub-53-minute session constitutes upcoding.
This is the single most common billing error we see with psychotherapy claims. A provider runs a 50-minute session, rounds up to 60 in their head, and submits 90837. The payer doesn’t round up. Neither does an auditor.
The 53-minute threshold isn’t arbitrary. It comes from midpoint math built into the CPT time rules, and once you see how it works, the logic clicks fast.
Psychotherapy Code Time Thresholds: Complete Table
| CPT Code | Session Label | Actual Time Required | Midpoint Logic | Typical Use |
| 90832 | 30 minutes | 16 to 37 minutes | Midpoint between 16 and 37 | Brief interventions, medication check-ins |
| 90834 | 45 minutes | 38 to 52 minutes | Midpoint between 38 and 52 | Standard weekly therapy sessions |
| 90837 | 60 minutes | 53+ minutes | Midpoint between 45 and 60+ | Extended sessions, trauma work, crisis care |
Here’s how the midpoint works for 90837: the AMA calculates the midpoint between 45 minutes (the 90834 target) and 60 minutes (the 90837 target). That midpoint is 52.5, which rounds up to 53. Hit 53 minutes of face-to-face therapy, and you’ve crossed into 90837 territory. Fall short by even one minute, and you’re in 90834 range.
That one minute is the difference between roughly $154 and $120 on a Medicare claim. It’s also the difference between a clean claim and a compliance problem.
What Counts as Face-to-Face Psychotherapy Time?
Not all time spent with a patient counts toward the 53-minute threshold. Here’s what does and doesn’t qualify.
Counts toward 90837 time:
- Direct therapeutic interaction with the patient
- Active psychotherapy interventions (CBT restructuring, EMDR processing, exposure work)
- Crisis intervention and safety planning
- Therapeutic processing and reflective discussion
- In-session assessments administered and discussed therapeutically, like a PHQ-9
Does NOT count:
- Waiting for the patient to arrive or log on for telehealth
- Scheduling, billing, or administrative conversation
- Documentation, note writing, or chart review
- Phone calls, emails, or care coordination
- Pre-session preparation or post-session consultation
One area that trips providers up: time spent with family members. It only counts toward 90837 if the patient is present AND the interaction is part of individual therapy, not family therapy. If the patient steps out while you talk to a parent or spouse, that time doesn’t count toward your 53 minutes.
How to Document Time Correctly: Two Accepted Methods
Time documentation errors cause more 90837 denials than almost any other factor. Two methods are accepted, but one is significantly stronger under audit.
Method 1, start and stop times (recommended):
“Psychotherapy session began at 2:05 PM and ended at 3:02 PM. Total face-to-face psychotherapy time: 57 minutes.”
Method 2, total minutes statement:
“57 minutes of individual, face-to-face psychotherapy provided.”
Both satisfy CMS documentation requirements. But start and stop times are harder to dispute in an audit. When an auditor sees “2:05 PM to 3:02 PM,” there’s no ambiguity. When they see “57 minutes” with no timestamps, they may request your scheduling records to verify.
If you’re only going to change one thing about your documentation after reading this guide, make it this: record start and stop times on every 90837 note.
What If the Patient Is Late?
Your patient shows up 15 minutes late to a scheduled 60-minute appointment. You provide 45 minutes of therapy before wrapping up. The code you bill is 90834, not 90837.
The reason is straightforward: CPT codes are based on actual face-to-face time delivered, not time scheduled. It doesn’t matter what the appointment was booked for. Forty-five minutes is 45 minutes. Billing 90837 for that session is upcoding, which is a compliance violation that can trigger recoupment and penalties.
What If the Session Runs Long?
Here’s the flip side, and it works in your favor. Say you’ve scheduled a 45-minute session. At minute 40, your patient discloses suicidal ideation for the first time. You spend the next 18 minutes on risk assessment, safety planning, and stabilization. Total face-to-face time: 58 minutes.
You can bill 90837 for that session. The code is retrospective: it’s based on what actually happened, not what was planned. Document the clinical reason the session extended beyond the scheduled time, and your claim is clean.
The pattern here is simple. Bill what you delivered. Document what you did and why. If the clock says 53 or more minutes of face-to-face psychotherapy, 90837 is correct. If it says 52 or less, 90834 is correct. No rounding, no estimating, no exceptions.
Accurate time documentation is one of the most critical components of clean claim submission. If your practice struggles with revenue cycle management workflows that catch time-based errors before claims go out, One O Seven RCM can help.
ICD-10 Codes for 90837: Which Diagnoses Support This Code?
CPT code 90837 can be billed with any ICD-10-CM diagnosis code that supports individual psychotherapy as a medically necessary treatment. The most commonly paired diagnoses include major depressive disorder (F32 to F33), generalized anxiety disorder (F41.1), PTSD (F43.10), and adjustment disorders (F43.2x). Selecting the most specific, highest-severity diagnosis code supported by your documentation improves claim acceptance rates.
Wrong diagnosis code pairing is one of the quieter revenue killers in behavioral health billing. It doesn’t always trigger an immediate denial. Sometimes it triggers a medical record request, which slows payment by 30 to 60 days. Other times it creates a pattern that flags your NPI for audit.
Most Common ICD-10 Codes Paired With 90837
| ICD-10 Code | Diagnosis | Notes |
| F32.0 to F32.9 | Major Depressive Disorder, Single Episode | Specify severity: mild, moderate, severe |
| F33.0 to F33.9 | Major Depressive Disorder, Recurrent | Specify severity |
| F41.1 | Generalized Anxiety Disorder | Very common pairing |
| F41.0 | Panic Disorder | Include agoraphobia context when applicable |
| F43.10 | Post-Traumatic Stress Disorder (PTSD) | Strong justification for extended sessions |
| F43.12 | PTSD, Chronic | Supports medical necessity for 90837 |
| F43.20 to F43.29 | Adjustment Disorders | Specify type: depressed mood, anxiety, mixed |
| F40.10 | Social Anxiety Disorder | Common in outpatient therapy settings |
| F42.2 | Obsessive-Compulsive Disorder | Supports ERP-based extended sessions |
| F31.x | Bipolar Disorders | Specify type and current episode |
| F60.3 | Borderline Personality Disorder | Strong justification for DBT-based 90837 |
| F90.x | ADHD | Less common for standalone psychotherapy |
| F50.x | Eating Disorders | Supports extended session justification |
| F10 to F19 | Substance Use Disorders | When psychotherapy is the primary intervention |
| F44.x | Dissociative Disorders | Strong justification for extended time |
Diagnoses like PTSD, borderline personality disorder, and dissociative disorders carry built-in clinical justification for longer sessions. When an auditor sees F43.10 paired with 90837, the extended time makes clinical sense without much explanation. Pair 90837 with F43.22 (adjustment disorder with anxiety), and you’ll need stronger documentation showing why 53-plus minutes was necessary for that presentation.
Diagnosis Codes That May Cause Denials With 90837
Some ICD-10 codes create friction when paired with 90837. Not because they’re invalid, but because payers question whether individual psychotherapy is the appropriate treatment.
Watch for these:
- Z-codes (Z71.1 counseling, Z63.0 relationship problems): many payers don’t cover psychotherapy for Z-code diagnoses
- Unspecified codes (F32.9, F41.9) when a more specific code is available: these often trigger medical record requests
- V-codes (legacy system): most payers no longer accept them
- Diagnoses not typically treated with individual psychotherapy: if the condition doesn’t call for one-on-one therapy, the pairing won’t make clinical sense to a reviewer
If you’re seeing record requests or soft denials with specific diagnosis codes, the code itself might be the trigger. Swap to a more specific code that’s supported by your clinical documentation, and the pattern usually stops.
Best Practices for Diagnosis Code Selection
- Code to the highest level of specificity your documentation supports
- Use the primary diagnosis that most directly justifies the need for psychotherapy
- List secondary diagnoses that add complexity and support extended session time
- Make sure the diagnosis matches the active treatment plan
- Update diagnosis codes as the clinical presentation evolves over time
The last point catches a lot of practices. A patient comes in for adjustment disorder, progresses to major depressive disorder six months later, but the billing still carries the original F43.2x code. That mismatch between documentation and diagnosis is exactly what triggers a medical record request, or worse, a recoupment.
Incorrect diagnosis code pairing is a leading cause of initial claim denials. Our medical billing team cross-references diagnosis-to-procedure code logic before every claim submission.
90834 vs 90837: Which Code Should You Bill?
The primary difference between 90834 and 90837 is session duration: 90834 covers 38 to 52 minutes of psychotherapy, while 90837 requires 53 or more minutes. Beyond time, the codes differ in reimbursement rates, documentation burden, payer scrutiny levels, and audit risk. Choosing between them should always be based on actual time delivered and clinical complexity, never reimbursement amount.
This sounds obvious. In practice, it’s where a lot of providers get into trouble.
Side-by-Side Comparison Table
| Factor | 90834 (45 min) | 90837 (60 min) |
| Time Required | 38 to 52 minutes | 53+ minutes |
| Medicare National Avg (2026) | ~$117 to $125 | ~$154 to $160 |
| Work RVUs (2026) | ~2.40 | ~3.07 |
| Documentation Burden | Standard | Higher: must justify extended time |
| Payer Scrutiny Level | Lower | Higher: frequently audited |
| Prior Auth Required | Rarely | Some payers after set number of sessions |
| Typical Use | Routine weekly therapy | Complex, crisis, trauma processing |
| Medical Necessity Bar | Standard | Must document need for 53+ minutes |
| Audit Risk | Low | Moderate to high |
The reimbursement gap is real: roughly $30 to $35 more per session on Medicare. Over a full caseload, that adds up fast. But the documentation and scrutiny gap is just as real, and ignoring it is what creates audit exposure.
When 90837 Is Clinically Appropriate
Extended sessions aren’t just about time. They’re about clinical complexity that requires more time. Here are the scenarios where 90837 makes sense and holds up under review:
- Complex trauma processing requiring extended stabilization
- Crisis intervention with safety planning and lethal means counseling
- EMDR sessions requiring completion of full protocol phases
- Multiple comorbid conditions addressed in a single session (PTSD plus substance use, for example)
- Initial intensive treatment phases for severe presentations
- DBT skills training combined with individual therapy components
- Disclosure of new traumatic material requiring extended processing
When the clinical picture demands more than 52 minutes, bill 90837 and document why. That’s clean billing.
When 90834 Is the Right Code (and Protects You From Upcoding Risk)
If the session naturally wraps up at 45 to 50 minutes, bill 90834. Don’t stretch a session to hit 53 minutes for the higher reimbursement. And don’t bill 90837 for a 48-minute session because “it was close enough.”
Situations where 90834 is the appropriate code:
- Routine maintenance therapy with stable patients
- Check-in sessions focused on homework review and goal monitoring
- Sessions that naturally conclude at 45 to 50 minutes
- Presentations where clinical complexity doesn’t warrant extended time
There’s no shame in billing 90834. It’s the workhorse code of outpatient psychotherapy for a reason.
The Upcoding Red Flag: 90837 Utilization Patterns
Here’s where the pattern matters more than any individual claim. If your practice bills 90837 for 80% or more of all psychotherapy claims, expect scrutiny. The OIG’s audit priorities specifically include mental health billing patterns, and a disproportionately high 90837 utilization rate relative to 90834 is one of the clearest flags.
A balanced code distribution, one that reflects genuine clinical variation across your caseload, is your best protection. Some patients need 53-plus minutes. Most routine weekly therapy patients don’t.
If you’re unsure about your practice’s utilization ratio, pull a report from your billing system. Compare total 90834 claims to total 90837 claims over the last six months. If 90837 dominates without a clear clinical reason across your patient population, that’s a pattern worth correcting before someone else notices it.
90837 Reimbursement Rates by Payer & RVU Breakdown (2026)
90837 reimbursement rates vary by payer, geographic region, provider credentials, facility vs. non-facility setting, and contract terms. Medicare’s 2026 national average for non-facility 90837 is approximately $154 to $160, based on a total RVU of roughly 4.25 multiplied by the 2026 conversion factor. Commercial payers range from $110 to $180+ depending on your contract.
If you’re getting paid less than expected on 90837 claims and can’t figure out why, three things usually explain it: wrong place of service code, missing geographic adjustment context, or a contract rate that’s lower than you realized when you signed.
How Medicare Calculates the 90837 Rate (RVU Breakdown)
Most providers see the payment amount on their ERA and move on. But knowing how Medicare builds that number helps you spot underpayments fast. Here’s the math behind your 90837 reimbursement.
| RVU Component | Non-Facility | Facility |
| Work RVUs | ~3.07 | ~3.07 |
| Practice Expense RVUs | ~1.03 | ~0.45 |
| Malpractice RVUs | ~0.15 | ~0.15 |
| Total RVUs | ~4.25 | ~3.67 |
| × Conversion Factor (2026) | ~$33.29 (est.) | ~$33.29 (est.) |
| Estimated Payment | ~$141 to $160 | ~$122 to $138 |
Geographic Practice Cost Index (GPCI) adjustments modify these figures by location.
Notice the gap between facility and non-facility. Work RVUs stay the same, but practice expense RVUs drop significantly in facility settings. That’s because Medicare assumes the facility covers overhead costs like rent, utilities, and staff. If your claim goes out with the wrong place of service code, you could be getting the facility rate for services you’re providing in private practice.
You can look up your exact locality rate using the CMS Physician Fee Schedule Search Tool. Takes about two minutes, and it gives you the number your payments should match.
Medicare 90837 Reimbursement Rates
Here’s how the national average has trended:
- 2026 National Average (Non-Facility): ~$154 to $160
- 2025 Rate: ~$154.29
- 2024 Rate: ~$149.64
- Facility Rate: ~$122 to $138 (significantly lower)
Geographic variation matters. Providers in urban California, New York, and Massachusetts see higher payments due to GPCI adjustments. Rural states typically fall on the lower end.
Patient cost sharing on Medicare 90837 claims:
- Medicare pays 80% of the approved amount
- Patient owes 20% coinsurance (roughly $31)
- Coinsurance applies after the annual Part B deductible is met ($257 in 2025)
- Medigap or supplemental plans may cover the patient’s portion
If you’re consistently collecting less than $154 on non-facility Medicare 90837 claims, check two things: your POS code and your GPCI locality. One of those is almost always the culprit.
Commercial Payer Rates (2026 Estimated Ranges)
| Payer | In-Network Range | Out-of-Network UCR | Prior Auth for 90837? |
| Blue Cross Blue Shield | $120 to $165 | $60 to $120 | Varies by plan |
| Aetna | $140 to $160 | $80 to $130 | Generally no |
| Cigna/Evernorth | $130 to $155 | $75 to $125 | Sometimes after 20 sessions |
| UnitedHealthcare/Optum | $110 to $150 | $70 to $120 | Removed for outpatient MH |
| Humana | $125 to $150 | $70 to $115 | Plan-dependent |
| Anthem | $130 to $160 | $75 to $125 | Varies |
| Tricare | $120 to $145 | N/A | No for outpatient |
| Kaiser (where applicable) | $135 to $155 | N/A | Internal referral |
| Magellan (managed BH) | $100 to $140 | N/A | Often required |
| Beacon/Carelon | $105 to $140 | N/A | Often required |
One pattern we see constantly: a provider is in-network with UnitedHealthcare but doesn’t realize Optum manages the behavioral health carve-out. Claims go to UHC, get rerouted, and payment takes 45 to 60 days instead of 14. Same thing happens with Cigna and Evernorth, or any plan that carves out behavioral health to a separate managed care entity.
These are estimated ranges based on industry data and provider reports. Your specific rate depends on your negotiated contract, geographic location, and provider credentials. Always verify with your payer representative or by reviewing your fee schedule.
Factors That Affect Your 90837 Reimbursement
If you’re seeing inconsistent payments across claims with the same CPT code, one of these factors is driving it:
- Geographic location (GPCI): metro areas pay higher, rural areas lower
- Provider credentials: MD and PhD typically reimburse higher than master’s-level providers
- Facility vs. non-facility: private practice (POS 11) pays more than hospital outpatient
- Your negotiated contract rate: this is the number that actually matters for commercial payers
- In-network vs. out-of-network status: significant gap, especially for patient responsibility
- Managed care carve-outs: behavioral health managed separately often means lower rates
- Modifier usage: telehealth modifiers can affect rates with some payers
The one most providers overlook is number six. Managed behavioral health organizations like Magellan and Carelon often negotiate rates independently from the medical plan. Your in-network rate with Anthem doesn’t guarantee the same rate with Anthem’s behavioral health carve-out partner.
Medicaid 90837 Rates by State (Selected)
Medicaid reimbursement for 90837 varies dramatically by state, and it’s almost always lower than Medicare or commercial rates:
- California (Medi-Cal): ~$90 to $110
- Texas: ~$85 to $100
- New York: ~$100 to $130
- Florida: ~$80 to $95
- Illinois: ~$90 to $105
Medicaid managed care organizations (MCOs) may pay differently than fee-for-service Medicaid within the same state. Contact your state’s MCO directly for exact rates. You can find state-specific resources at Medicaid.gov.
If you’re consistently seeing underpayments or inconsistent reimbursement across payers, your revenue cycle management process may need a closer look. One O Seven RCM identifies underpayments systematically and recovers revenue that’s slipping through.
Underpaid claims that go unnoticed often age past appeal deadlines and become permanent losses. Our AR follow-up team pursues every dollar owed to your practice before that window closes.
90837 Documentation Requirements: What Auditors Actually Look For
Proper documentation for CPT code 90837 must demonstrate four elements: exact session duration of 53+ minutes, medical necessity for extended time, specific therapeutic interventions used, and patient response with clinical progress. The Office of Inspector General (OIG) has specifically identified psychotherapy documentation deficiencies as a focus area, making this the highest-risk part of your 90837 billing process.
Here’s the pattern we see over and over: the claim goes out clean, gets paid, and nobody thinks about documentation until an audit request lands in the inbox six months later. By then, the notes either support the claim or they don’t. There’s no fixing it retroactively.
The Six Essential Documentation Elements
Every 90837 note needs these six components. Miss one, and you’ve created audit exposure.
1. Session time documentation
Record start and stop times or total minutes. The note must show 53+ minutes of face-to-face therapy. Medicare explicitly requires time in the medical record. Use start and stop format: it’s harder for an auditor to dispute “2:05 PM to 3:02 PM” than “57 minutes.”
2. Medical necessity justification for extended duration
Why did this patient need 53-plus minutes today? Not last week, not generally. Today. Link the extended time to specific treatment plan goals and clinical factors. Generic language doesn’t cut it here.
3. Specific therapeutic interventions
Name the modality. Describe what you actually did. “Cognitive restructuring targeting catastrophic thought patterns about job loss” passes audit review. “Provided psychotherapy” doesn’t. Neither does “supportive therapy provided.”
4. Patient presentation and mental status
Document appearance, mood, affect, and thought process. Include relevant behavioral observations, symptom severity indicators, and risk assessment for suicidal or homicidal ideation when applicable.
5. Patient response to interventions
How did the patient respond to today’s work? Did you see shifts in affect, cognition, or behavior during the session? Were there barriers? Auditors want to see that the interventions produced a clinical interaction, not just that time passed.
6. Treatment plan connection and next steps
Which treatment plan goals were addressed? What’s the measurable progress? Include homework or between-session assignments, the plan for the next session, and follow-up timeline.
How to Justify Medical Necessity for 90837
This is where 90837 claims either hold up or fall apart under review. Medical necessity isn’t about the time you scheduled. It’s about the clinical reason the patient needed extended time on that specific date.
Strong clinical justifications (these hold up):
- “Patient presented in acute suicidal crisis requiring extended safety planning, means restriction counseling, and stabilization. Session could not be safely concluded at 45 minutes.”
- “EMDR reprocessing required completion of full desensitization phase to avoid leaving patient in elevated distress. Processing required 58 minutes.”
- “Complex comorbid presentation (PTSD, MDD, alcohol use disorder) required extended session to address trauma processing and relapse prevention within an integrated treatment framework.”
- “Patient disclosed childhood sexual abuse for the first time, requiring extended therapeutic containment, grounding interventions, and safety assessment.”
Weak justifications (these get flagged):
- ❌ “Standard 60-minute session”: no clinical rationale
- ❌ “Patient requested longer session”: preference isn’t necessity
- ❌ “Scheduled for 60 minutes”: scheduling isn’t documentation
- ❌ “Continued from last session”: doesn’t justify today’s time
- ❌ “Complex patient”: too vague, specify what’s complex
If you can’t articulate in one sentence why 53-plus minutes was clinically necessary for this patient on this date, you don’t have sufficient justification for 90837.
Sample Progress Note Framework for 90837
This framework meets documentation standards for Medicare, commercial payers, and OIG audit requirements. Customize it to fit your EHR system.
SESSION INFORMATION:
Date: [Date] | Session Start: [Time] | Session End: [Time]
Total Face-to-Face Psychotherapy Time: [XX] minutes
CPT Code: 90837 | Modifiers: [if applicable]
CLINICAL JUSTIFICATION FOR EXTENDED SESSION:
[Specific reason 53+ minutes was clinically necessary today]
PATIENT PRESENTATION:
[Mental status observations, symptom severity, risk assessment]
INTERVENTIONS PROVIDED:
[Specific therapeutic modalities and techniques used]
PATIENT RESPONSE:
[How patient responded to interventions, in-session changes]
PROGRESS TOWARD TREATMENT PLAN GOALS:
Goal #[X]: [Goal description] — [Progress indicator]
PLAN:
[Next session focus, homework, follow-up timeline]
The “Clinical Justification for Extended Session” line is the one most providers skip. It’s also the one auditors look for first. Adding that single field to your note template takes 30 seconds per session and eliminates the most common 90837 documentation gap.
OIG and MAC Audit Findings: What Actually Goes Wrong
When audits target 90837 claims, they find the same problems over and over. Here’s what Medicare Administrative Contractors and OIG reviews consistently flag:
- Missing time documentation: the most common error, and the easiest to prevent
- Missing or outdated treatment plans
- Missing provider signatures
- Templated notes without individualization (copy-paste from previous sessions)
- No medical necessity justification for 90837 over 90834
- Incomplete risk assessments
- Diagnosis in the claim not supported by content in the note
That last one is subtle but costly. Your claim says F43.10 (PTSD), but your progress note describes general stress management with no trauma-focused content. An auditor reads that as a mismatch, and the claim gets recouped.
Documentation deficiencies are the number one cause of claim denials in behavioral health. One O Seven RCM’s medical billing team reviews documentation against payer requirements before claims go out, catching errors before they become denials or audit liabilities.
How to Bill 90837 for Telehealth: Modifiers, POS Codes & 2026 Rules
Yes, CPT code 90837 can be billed for telehealth psychotherapy sessions. For synchronous video telehealth, append modifier 95 and use Place of Service (POS) code 10 (patient at home) or 02 (patient at distant site). For audio-only sessions under Medicare, use modifier 93 with POS 02. Always verify payer-specific requirements, as telehealth policies continue to evolve in 2026.
Telehealth 90837 denials usually come down to three things: wrong modifier, wrong POS code, or a payer policy that changed without anyone noticing. Get any of these wrong, and the claim bounces.
90837 Telehealth Modifier Guide
| Modifier | Description | When to Use | Payer Acceptance |
| 95 | Synchronous audio-video telehealth | Video sessions (standard modifier) | Medicare + most commercial payers |
| GT | Interactive audio/video telecommunications | Legacy modifier (being phased out) | Some payers still require |
| 93 | Audio-only (telephone) telehealth | Medicare behavioral health services | Medicare; some Medicaid |
| FQ | Telehealth from FQHC | Federally Qualified Health Centers | Medicare |
| FR | Supervising practitioner via telehealth | Teaching settings | Medicare |
Modifier 95 is the standard for video-based telehealth with most payers. But here’s where it gets messy: some commercial payers still want GT on their claims, even though CMS phased it out. If you’re getting denials on telehealth claims and the session was legitimate, check whether that specific payer requires a different modifier.
Place of Service (POS) Codes for Telehealth 90837
| POS Code | Description | When to Use | Impact on Reimbursement |
| 10 | Telehealth: Patient’s Home | Patient at home (most common for mental health) | Non-facility rate (higher reimbursement) |
| 02 | Telehealth: Other Than Home | Patient at clinic, school, or other site | May trigger facility rate (lower) |
This is where money gets left on the table. POS 10 generally reimburses at the non-facility rate, which is roughly $20 to $30 higher per session than the facility rate. POS 02 may trigger the lower facility rate depending on the payer. For behavioral health telehealth from the patient’s home, use POS 10 to ensure you’re getting paid correctly.
Medicare Telehealth Rules for 90837 (2026 Update)
Medicare’s telehealth flexibilities have been extended multiple times since the pandemic. Here’s the current status, but verify against CMS Telehealth Services before relying on it:
- Telehealth flexibilities: Extended through current legislation; check CMS for exact dates
- In-person requirement: Delayed or waived for mental health services
- Audio-only (modifier 93): Permitted for behavioral health and SUD services
- Geographic restrictions: Currently relaxed with no originating site restrictions for mental health
- Provider-patient relationship: Can be established via telehealth
Telehealth policy is one of the most rapidly changing areas in healthcare billing. What’s accurate today may not be accurate in six months. Always verify current CMS guidance before assuming any published source, including this one, reflects current rules.
Commercial Payer Telehealth Policies for 90837
Each payer handles telehealth differently, and the variations matter:
- Aetna: Generally accepts modifier 95 with POS 10; offers parity with in-person rates in many states
- BCBS: Varies by state entity; most accept modifier 95
- UnitedHealthcare: Modifier 95, POS 02 or 10; verify plan-specific rules
- Cigna: Modifier 95; some legacy plans still require GT
Many states now have telehealth parity laws requiring insurers to reimburse telehealth at the same rate as in-person services. Check the Center for Connected Health Policy for your state’s specific requirements.
Telehealth Documentation Add-Ons
Your 90837 telehealth notes need a few additional elements beyond standard documentation:
- Technology platform used (must be HIPAA-compliant)
- Patient location and state (this affects licensure)
- Verbal or written consent for telehealth on file
- Any technical issues and how they were resolved
- Actual face-to-face psychotherapy time, accounting for any tech delays
- Verification of patient identity
Interstate Licensing: The Hidden Compliance Risk
You must hold an active license in the state where the patient is physically located at the time of the session. Not where your office is. Not where the patient usually lives. Where they’re sitting when you’re on the call.
The Psychology Interjurisdictional Compact (PSYPACT) and Counseling Compact allow qualifying providers to practice across member states without holding multiple individual licenses. Check whether your state participates and whether your license type qualifies.
Telehealth billing rules change frequently, and incorrect modifier or POS code usage is a top denial trigger. One O Seven RCM’s medical billing team stays current on every payer’s telehealth requirements, so your claims go out correctly the first time.
Billing 90837 With Other Codes on the Same Day: Rules, Modifiers & Add-Ons
You can bill 90837 with certain other codes on the same day, but specific rules govern which combinations are allowed. When psychotherapy and medication management are provided in the same visit, use an E/M code plus psychotherapy add-on codes, not standalone 90837 plus E/M. Billing 90837 twice in one day is possible but requires two truly separate encounters with independent medical necessity documentation.
This is one of the areas where we see the most preventable denials. Providers do the work correctly but bill it incorrectly, and the claim comes back denied.
90837 With E/M Codes (Psychiatry Split-Visit Billing)
When a psychiatrist provides both psychotherapy and medication management in the same visit, here’s the correct billing structure:
- Bill the E/M code (99213, 99214, etc.) for the medical and medication management portion
- Add the psychotherapy add-on code based on therapy time:
- +90833 for 16 to 37 minutes of psychotherapy
- +90836 for 38 to 52 minutes of psychotherapy
- +90838 for 53+ minutes of psychotherapy
- Append modifier 25 to the E/M code
- Document E/M time and psychotherapy time separately
The common error: Billing standalone 90837 plus standalone 99214 on the same day. This will typically get denied or flagged. The correct approach is E/M code with modifier 25 plus the psychotherapy add-on.
Example: A psychiatrist provides 20 minutes of medication management and 55 minutes of psychotherapy in the same visit.
- Correct: 99214-25 + 90838
- Incorrect: 99214 + 90837
Understanding Modifier 25 With 90837
Modifier 25 indicates a “significant, separately identifiable E/M service” performed by the same physician on the same day as another procedure. When billing E/M plus a psychotherapy add-on, modifier 25 on the E/M code tells the payer that the medical evaluation was distinct from the therapy service.
Without modifier 25, the payer may bundle the E/M into the psychotherapy and pay only for one service. That’s money you earned but won’t collect.
Can You Bill 90837 Twice in One Day?
Billing 90837 twice in one day is permissible only when there are two completely separate, distinct encounters. Each session must have independent medical necessity, separate documentation, separate session times, and clear clinical justification for why two extended sessions were required on the same date. This is clinically unusual, significantly increases audit risk, and should be rare in practice.
If you’re going to bill 90837 twice on the same date, you need:
- Two distinct sessions with separate start and stop times
- Separate progress notes for each session
- Clear medical necessity for each (for example, morning crisis session plus evening stabilization)
- Modifier 76 (repeat procedure by same physician) or 59 (distinct procedural service)
- Payer pre-approval is recommended
If you’re billing 90837 twice in one day more than occasionally, that’s a pattern that will attract audit attention.
90837 Add-On Codes
Interactive Complexity (+90785)
Add this to 90837 when specific complexity factors are present:
- Communication difficulties requiring an interpreter or accommodating cognitive impairment
- Third-party involvement such as custody disputes, law enforcement, or CPS
- Maladaptive communication patterns that complicate treatment delivery
You must document the specific complexity factor in your note. Don’t add 90785 just because the session was difficult. The complexity must fit one of the defined categories. When documented correctly, it adds approximately $15 to $25 to reimbursement.
90837 NCCI Edits You Must Know
National Correct Coding Initiative (NCCI) edits create automatic conflicts between certain code pairs. For 90837, the key edits are:
- 90837 is mutually exclusive with 90832 and 90834 on the same day from the same provider
- 90837 bundles with certain crisis codes; check current edits before billing
- Modifier usage can bypass some edits when clinically appropriate and documented
If you’re getting denials for same-day code combinations that should be billable, check the NCCI edit file. The conflict might be an edit issue, not a clinical documentation issue.
How to Bill Psychotherapy Sessions Longer Than 60 Minutes
Billing for psychotherapy sessions longer than 60 minutes has changed significantly since 2023. The prolonged service codes 99354 and 99355 were deleted effective January 1, 2023, and the replacement code G2212 applies only to E/M services, not standalone psychotherapy like 90837. Options for reimbursing extended psychotherapy time are now limited and payer-specific.
This catches a lot of providers off guard. You run a 90-minute EMDR session, look for a prolonged services code to capture the extra time, and discover it doesn’t exist anymore.
Current Options for Sessions Over 60 Minutes
Option 1: Bill 90837 for the Full Session
90837 has no upper time limit. A 75-minute session is still 90837. So is a 90-minute session. Document your actual time and the clinical necessity for the extended duration. The downside: reimbursement is the same whether you provided 53 minutes or 90 minutes.
Option 2: Some Payers Allow Two Units of 90837
For sessions lasting 106 minutes or longer (53 minutes times two), some payers permit billing two units of 90837. Each “unit” requires independent documentation, and you’ll need to verify with your specific payer before billing this way. This carries high audit risk and should only be used with clear payer approval in writing.
Option 3: Split-Bill E/M Plus Psychotherapy Add-On
If medication management is also provided during the extended session, you can use an E/M code plus the 90838 add-on (53+ minutes of psychotherapy). Document the E/M time and the psychotherapy time separately. This only works when both services are genuinely rendered; you can’t manufacture an E/M component just to capture more time.
What NOT to Do
- ❌ Billing 99354 or 99355 with 90837: These codes were deleted as of January 1, 2023
- ❌ Using G2212 with 90837: G2212 is for E/M prolonged services only, not psychotherapy
- ❌ Billing multiple units of 90837 without payer verification: This will get denied or trigger an audit
- ❌ Time stacking codes to inflate reimbursement: This is a compliance violation
- ❌ Splitting one continuous session into two claims without clinical justification: This is also a compliance violation
The honest reality is that extended psychotherapy sessions beyond 60 minutes aren’t well-compensated under the current coding structure. You can document the time, but you won’t capture additional reimbursement in most cases unless the payer has a specific policy allowing it.
Extended session billing is complex, payer-specific, and constantly evolving. One O Seven RCM’s medical billing specialists can help you understand your options and maximize legitimate reimbursement for every minute of clinical work you provide.
90837 Claim Denials: Top 12 Reasons & How to Prevent Each One
CPT code 90837 claims face higher denial rates than any other standalone psychotherapy code due to increased payer scrutiny around session time, medical necessity, and utilization patterns. The average behavioral health practice loses 5% to 10% of 90837 revenue to preventable denials. Understanding the most common denial reasons, and implementing systematic prevention, protects your revenue.
Most 90837 denials aren’t random. They follow patterns. Once you know what triggers them, you can build prevention into your workflow instead of chasing appeals after the fact.
Top 12 Reasons for 90837 Denials (With Prevention)
| # | Denial Reason | CARC/RARC Code | Prevention Strategy |
| 1 | Missing time documentation | CO-16, N386 | Document start and stop times every session |
| 2 | Session under 53 minutes | CO-4 | Bill 90834 if actual time is 38 to 52 minutes |
| 3 | Lack of medical necessity | CO-50 | Document clinical justification for extended time |
| 4 | Frequency or utilization exceeded | OA-18 | Verify payer limits; obtain prior authorization |
| 5 | Prior authorization missing | CO-197 | Check auth requirements per payer and plan |
| 6 | Telehealth modifier missing/incorrect | CO-4, MA-130 | Use modifier 95 (video) or 93 (audio-only) |
| 7 | Provider not credentialed | CO-185 | Verify active credentialing before billing |
| 8 | Diagnosis not covered | CO-50, CO-167 | Verify ICD-10 coverage; avoid unsupported Z-codes |
| 9 | Duplicate claim | CO-18 | Check submission history before rebilling |
| 10 | Timely filing exceeded | CO-29 | Know each payer’s filing deadlines |
| 11 | Coordination of benefits issue | OA-22 | Verify primary and secondary payer order |
| 12 | Place of service incorrect | CO-4 | Ensure POS matches setting (11, 02, 10) |
If you’re seeing the same CARC codes repeatedly across multiple claims, that’s not bad luck. It’s a workflow gap. The denial is just the symptom.
How to Appeal 90837 Denials: Step-by-Step
- Identify the denial reason code. Read the remittance advice carefully. The CARC and RARC codes tell you exactly why the claim was denied.
- Determine if it’s correctable or appealable. Some denials need a corrected claim (wrong modifier, missing info). Others need a formal appeal (medical necessity disputes).
- Gather supporting documentation. Pull the clinical note, time records, treatment plan, and any authorization records.
- Write the appeal letter. Address the specific denial reason with evidence, not generic language.
- Include these key elements:
- Patient name, DOB, claim number, date of service
- Specific denial reason being appealed
- Clinical documentation supporting the claim
- Reference to the payer’s own policy supporting coverage
- Clear request for specific action (reprocess, pay, etc.)
- Submit within the payer’s appeal window. Most payers allow 30 to 180 days. Miss the window and the denial becomes permanent.
- Track and follow up. Log the appeal, set a follow-up date, and escalate if you don’t get a response.
Sample Appeal Letter Framework for 90837 Denial
[Date]
[Payer Name and Address]
Re: Appeal for Denied Claim
Patient: [Name] | DOB: [DOB] | Member ID: [ID]
Date of Service: [DOS] | CPT Code: 90837
Claim Number: [Number] | Denial Reason: [Code/Description]
Dear Claims Review Department,
I am writing to appeal the denial of the above-referenced claim
for CPT code 90837 (psychotherapy, 60 minutes). The denial reason
stated [specific reason]. I respectfully disagree with this
determination for the following reasons:
[Insert 2 to 3 specific clinical or administrative justifications]
Enclosed documentation includes:
☐ Progress note with documented session time of [XX] minutes
☐ Treatment plan supporting medical necessity
☐ [Additional supporting documentation]
Based on [payer’s own medical policy/AMA guidelines/CMS guidelines],
this service meets all criteria for coverage and payment. I
respectfully request that this claim be reprocessed for payment.
Sincerely,
[Provider Name, Credentials]
[NPI Number]
Customize this for each denial. Generic appeal letters get generic rejections.
Claim denials cost your practice time, money, and administrative bandwidth. One O Seven RCM’s denial management team identifies denial patterns, writes appeals, and recovers revenue so your staff can focus on patient care.
Denied claims that aren’t appealed within payer deadlines become lost revenue permanently. Our AR follow-up process ensures no claim falls through the cracks.
90837 Payer-Specific Policies: What Each Major Insurer Requires
Every payer handles 90837 differently. What works for Medicare won’t necessarily work for BCBS. What Aetna accepts, Magellan might deny. Knowing payer-specific requirements before you submit prevents denials that shouldn’t happen in the first place.
Medicare 90837 Requirements
- Time documentation: Mandatory in the medical record
- Medical necessity: Expected and actively audited
- Prior authorization: Not typically required for outpatient psychotherapy
- Telehealth: Modifier 95 for video, modifier 93 for audio-only, POS 10 or 02
- Incident-to billing: Possible under specific conditions (see next section)
- Claims submission: CMS-1500 or electronic 837P
Medicare is straightforward on the rules but aggressive on audits. Document time, document necessity, and don’t bill 90837 when 90834 is the correct code.
Blue Cross Blue Shield 90837 Policies
- 53-minute rule applies across all BCBS entities
- Prior auth may be required after 20 to 30 sessions, depending on the plan
- Telehealth accepted with modifier 95, generally covered at parity
- In-network rates typically range from $120 to $165
- Medical record requests are common for high-utilization providers
BCBS is a federation, not a single payer. Rules vary by state entity. What Florida Blue requires may differ from Anthem Blue Cross. Always verify with the specific BCBS entity on the patient’s card.
Aetna 90837 Policies
- Medical necessity documentation required
- Telehealth covered with modifier 95
- Check specific plan for authorization requirements
- Meritain Health (Aetna subsidiary) may have different rules than standard Aetna plans
UnitedHealthcare / Optum Behavioral Health
- Prior auth requirements removed for most outpatient mental health (verify current status)
- Optum manages behavioral health for many UHC plans
- Telehealth accepted with modifier 95 and POS 10
- Care advocacy outreach: Optum may contact providers about utilization patterns
Here’s the pattern we see constantly: a provider is credentialed with UnitedHealthcare but doesn’t realize Optum manages the behavioral health benefits. Claims go to UHC, get rerouted to Optum, and payment takes 45 to 60 days instead of 14.
Cigna / Evernorth Behavioral Health
- Documentation requirements align with AMA standards
- Telehealth covered
- Rate ranges typically $130 to $155
- Evernorth manages behavioral health for Cigna; submit claims through Evernorth, not Cigna directly
Managed Behavioral Health Organizations (MBHOs)
This is where a lot of practices get blindsided. Many commercial plans carve out behavioral health to a separate managed care entity. The patient’s medical benefits go through one payer; mental health benefits go through another.
- Magellan Health: Often requires prior authorization for 90837; rates tend to run lower than primary insurers
- Carelon Behavioral Health (formerly Beacon): Authorization may be required after initial sessions
- New Directions / Lucet: Verify behavioral health carve-out status before submitting
If you’re submitting 90837 claims to the primary insurer when a behavioral health carve-out manages the mental health benefits, the claim will be denied. Not for clinical reasons. For administrative routing.
Always verify whether your patient’s mental health benefits are managed by the primary insurer or a behavioral health carve-out. One phone call to the number on the back of the insurance card takes five minutes and prevents a denial that takes 30 minutes to appeal.
Payer policies change frequently. Always verify current requirements directly with the payer or their provider portal before assuming any published guidance is current.
Keeping up with payer policy changes across multiple insurers is a full-time job. One O Seven RCM monitors payer updates continuously as part of our revenue cycle management services, so your claims are always compliant and optimized.
Incident-To Billing for 90837: Rules, Requirements & Risks
Under Medicare’s incident-to billing rules, a psychotherapy session (including 90837) provided by a non-physician practitioner (NPP), such as an LCSW, LPC, or LMFT, can potentially be billed under the supervising physician’s NPI at 100% of the physician fee schedule, rather than the NPP’s reduced rate (typically 85%). However, strict requirements must be met, and violations carry significant penalties.
The financial upside is real. So is the compliance risk. Most practices that attempt incident-to billing get at least one requirement wrong.
Incident-To Requirements for 90837
All five of these must be true for incident-to billing to apply:
- The supervising physician must have initiated the treatment plan
- The supervising physician must be physically present in the office suite (not just the building)
- The patient must be established (not a new patient)
- The service must be part of an ongoing treatment plan that the physician created
- The NPP must be an employee of, or working under arrangement with, the supervising physician’s practice
Miss any one of these, and incident-to billing doesn’t apply. Bill it anyway, and you’ve created a compliance problem.
When Incident-To Does NOT Apply
- Medicare Advantage plans: Different rules; verify with the specific MA plan
- Telehealth sessions: Incident-to generally doesn’t apply when services are delivered via telehealth
- Hospital outpatient departments: Different payment system entirely
- Supervising physician not on-site: If the MD isn’t physically present in the office suite, incident-to doesn’t work
Financial Impact of Incident-To Billing
Here’s the math that makes incident-to attractive:
- LCSW billing under own NPI (Medicare): 85% of physician rate = ~$131 to $136
- LCSW billing incident-to (under MD NPI): 100% of physician rate = ~$154 to $160
- Potential additional revenue per session: ~$23 to $24
- For a full-time therapist seeing six patients per day: ~$575 to $600 per week in additional revenue
That’s roughly $25,000 to $30,000 per year per therapist. The incentive is obvious.
But improper incident-to billing is a known OIG enforcement target. If you can’t meet all five requirements consistently, bill under the NPP’s own NPI at 85%. The 15% difference isn’t worth the audit exposure.
Incident-to billing requires proper credentialing of both the supervising physician and the NPP. One O Seven RCM handles credentialing and contracting for group practices to ensure all providers are properly enrolled and compliant.
90837 Compliance Checklist & Audit Preparation Guide
Is 90837 frequently audited? Yes. More than any other standalone psychotherapy code. Payers and OIG target 90837 because it’s high-volume, high-value, and high-risk for upcoding. The practices that survive audits without recoupment are the ones that built compliance into their workflow before the audit notice arrived.
Pre-Billing Compliance Checklist for 90837
Run through this checklist before every 90837 claim goes out. Missing even one element creates audit exposure.
- Session time documented (53+ minutes face-to-face)
- Start and stop times or total time statement included
- Medical necessity for extended session documented
- Specific therapeutic interventions named (not generic)
- Patient presentation and response documented
- Diagnosis code supported by clinical documentation
- Diagnosis code covered by the payer for psychotherapy
- Treatment plan current (updated within 90 days or per payer requirement)
- Provider signature present
- Telehealth modifiers correct (if applicable)
- POS code correct for setting
- Prior authorization obtained (if required by payer)
- Patient eligibility verified for date of service
- Credentialing active with the billed payer
- Claim submitted within timely filing window
If your billing workflow doesn’t include a version of this checklist, you’re relying on memory. Memory fails. Checklists don’t.
90837 Utilization Benchmarks: Know Your Numbers
Payers and OIG use utilization benchmarks to identify outlier billing patterns. No specific percentage is automatically “wrong,” but certain patterns trigger review.
- National average: Roughly 35% to 45% of psychotherapy claims are 90837 (estimated)
- Red flag threshold: If 80%+ of your psychotherapy claims are 90837, expect scrutiny
- What to monitor: Your 90834-to-90837 ratio, tracked monthly
- Protection strategy: Document clinical rationale when your utilization pattern runs higher than average
Pull a utilization report from your billing system every month. If 90837 dominates your code distribution without a clinical reason across your patient population, that’s a pattern worth correcting before an auditor notices it.
What to Do If You’re Audited
- Don’t panic. Respond professionally within the stated deadline. Rushing creates errors.
- Assess the scope. A single-claim request is different from a RAC audit, ZPIC investigation, or OIG review. For large-scope audits, engage compliance counsel.
- Gather exactly what’s requested. Provide what the auditor asks for. Nothing more, nothing less.
- Review your documentation before submitting. Make sure the notes demonstrate time, medical necessity, and specific interventions. If they don’t, that’s what the auditor will find too.
- Know your appeal rights. Unfavorable audit findings can be appealed. Deadlines vary by audit type.
- Implement corrective action. Whatever the audit identified, fix it going forward. Repeat findings in future audits carry worse consequences.
Audit preparation starts long before the audit notice arrives. One O Seven RCM builds compliance into every step of our medical billing process, ensuring your claims are audit-ready from day one.
90837 CPT Code FAQ: 22 Questions Answered
What is CPT code 90837?
CPT code 90837 is the billing code for individual psychotherapy sessions lasting 53 minutes or longer. Defined by the American Medical Association as “Psychotherapy, 60 minutes with patient,” it is the highest-level standalone psychotherapy code and covers face-to-face therapeutic interventions including CBT, EMDR, DBT, and other evidence-based modalities.
What is the difference between 90834 and 90837?
The key difference is session duration: 90834 covers 38 to 52 minutes of face-to-face psychotherapy, while 90837 requires 53 or more minutes. 90837 reimburses 15% to 25% higher but faces significantly more payer scrutiny, requires medical necessity documentation justifying extended time, and carries higher audit risk.
How many minutes is a 90837 session?
A 90837 session requires a minimum of 53 minutes of face-to-face psychotherapy time. While labeled as a “60-minute” code, the billable threshold begins at 53 minutes based on AMA midpoint time rules. Sessions of 52 minutes or less must be billed as 90834.
What is the reimbursement rate for 90837?
90837 reimbursement varies by payer and location. Medicare’s 2026 national average is approximately $154 to $160 (non-facility). Commercial payers range from $110 to $180: BCBS typically pays $120 to $165, Aetna $140 to $160, UnitedHealthcare $110 to $150, and Cigna $130 to $155. Actual rates depend on your contract and region.
How much does Medicare pay for 90837?
Medicare pays approximately $154 to $160 for CPT code 90837 in 2026 (national average, non-facility rate). The facility rate is lower at approximately $122 to $138. Geographic adjustments (GPCI) affect the rate by location. Medicare covers 80%; the patient pays 20% coinsurance after meeting the Part B deductible.
Can 90837 be billed for telehealth?
Yes, 90837 can be billed for telehealth psychotherapy sessions. For video telehealth, append modifier 95 with POS code 10 (patient at home) or 02 (patient at other site). For Medicare audio-only sessions, use modifier 93. Verify each payer’s specific telehealth requirements, as policies vary.
What modifier goes with 90837 for telehealth?
For telehealth 90837, use modifier 95 for synchronous video sessions (most widely accepted). Some payers still require modifier GT. For Medicare audio-only behavioral health services, use modifier 93. Always check payer-specific modifier requirements before submitting.
Can you bill 90837 twice in one day?
You can bill 90837 twice in one day only if there are two separate, distinct, medically necessary encounters with independent documentation. This is clinically unusual, carries high audit risk, and requires modifiers 76 or 59. Most payers will flag or deny duplicate 90837 claims without strong justification.
Is 90837 medically necessary?
Medical necessity for 90837 must be documented in the clinical note. Valid justifications include complex trauma processing, severe symptom presentations requiring intensive intervention, crisis stabilization, EMDR protocol completion, multiple comorbidities addressed simultaneously, or new traumatic disclosures requiring extended therapeutic processing.
How to justify 90837?
Justify 90837 by documenting specific clinical reasons for extended session time: crisis stabilization, complex trauma processing, severe symptom exacerbation, EMDR protocol needs, multiple comorbidities, or new disclosure requiring containment. A generic note like “60-minute session” or “patient wanted longer session” does not meet medical necessity standards.
Can you bill 90837 without a patient present?
No. CPT code 90837 requires face-to-face time with the patient. It cannot be billed for collateral contacts without the patient present, family-only sessions (use 90846), phone calls to other providers, care coordination, chart review, or documentation time.
What are the guidelines for billing 90837?
90837 billing guidelines require: (1) minimum 53 minutes of face-to-face psychotherapy, (2) documented session time, (3) medical necessity justification for extended duration, (4) appropriate covered ICD-10 diagnosis code, (5) active provider credentialing with the payer, and (6) correct modifiers and POS codes for the service setting.
How do I bill for 2 hours of psychotherapy?
For sessions lasting 90+ minutes, options are limited. Prolonged service codes 99354 and 99355 were deleted in 2023, and G2212 does not apply to 90837. Some payers allow two units of 90837 for 106+ minute sessions; others do not. Contact your specific payer for current policy before billing.
Is there an age limit for 90837?
There is no specific age limit for CPT code 90837. It can be billed for individual psychotherapy with children, adolescents, adults, and geriatric patients, provided the session meets the 53-minute minimum and the extended time is clinically appropriate for the patient’s age and developmental level.
What add-on codes work with 90837?
The primary add-on code for 90837 is +90785 (interactive complexity), which can be billed when specific complexity factors exist such as interpreter use, third-party involvement, or communication difficulties. Prolonged service codes 99354 and 99355 were deleted in 2023 and cannot be used with 90837.
What ICD-10 codes are used with 90837?
Common ICD-10 codes paired with 90837 include: F32 and F33 (major depressive disorder), F41.1 (generalized anxiety disorder), F43.10 (PTSD), F43.2x (adjustment disorders), F60.3 (borderline personality disorder), F42.2 (OCD), and F50.x (eating disorders). Any mental health diagnosis that supports individual psychotherapy as treatment can be paired with 90837.
Does 90837 require prior authorization?
Prior authorization requirements for 90837 vary by payer and plan. Medicare generally does not require prior auth for outpatient psychotherapy. Some commercial payers and managed behavioral health organizations (like Magellan or Carelon) require auth after a certain number of sessions. Always verify with the specific payer before beginning treatment.
What is the facility vs non-facility rate for 90837?
The non-facility rate for 90837 (private practice, outpatient clinic) is higher than the facility rate (hospital outpatient department). For Medicare in 2026, the non-facility rate is approximately $154 to $160, while the facility rate is approximately $122 to $138. The difference reflects lower practice expense RVUs in facility settings.
Can an LCSW bill 90837?
Yes, Licensed Clinical Social Workers (LCSWs) can bill CPT code 90837 for individual psychotherapy sessions of 53+ minutes. LCSWs must be licensed in the state where services are rendered and credentialed with the payer. Under Medicare, LCSWs are reimbursed at 85% of the physician fee schedule unless billing incident-to a supervising physician.
Can a PMHNP bill 90837?
Yes, Psychiatric-Mental Health Nurse Practitioners (PMHNPs) can bill CPT code 90837. PMHNPs are recognized by Medicare and most commercial payers as eligible psychotherapy providers. Under Medicare, PMHNPs are reimbursed at 85% of the physician fee schedule, unless billing incident-to a supervising physician at 100%.
What is the RVU for 90837?
The total RVU for CPT code 90837 (non-facility) is approximately 4.25, consisting of approximately 3.07 work RVUs, 1.03 practice expense RVUs, and 0.15 malpractice RVUs. Multiply total RVUs by the Medicare conversion factor (~$33.29 in 2026) and your geographic adjustment to calculate the estimated Medicare payment.
Does 90837 cover group therapy?
No. CPT code 90837 is exclusively for individual (one-on-one) psychotherapy. Group therapy is billed under CPT code 90853 (group psychotherapy, other than of a multiple-family group). Family therapy is billed under 90846 (without patient present) or 90847 (with patient present).
Still have questions about 90837 billing, documentation, or denials? One O Seven RCM’s behavioral health medical billing specialists are here to help.
Mastering CPT Code 90837: Key Takeaways for Your Practice
Here’s what matters most from everything covered in this guide:
- CPT code 90837 requires 53+ minutes of documented face-to-face psychotherapy. Not 60 minutes. Not “about an hour.” Fifty-three minutes minimum.
- Documentation must include session time AND medical necessity justification. Time alone isn’t enough. You need to explain why this patient needed extended time on this specific date.
- Pair with the most specific ICD-10 code supported by your clinical documentation. Unspecified codes trigger record requests. Z-codes often aren’t covered.
- Reimbursement varies by payer ($110 to $180+ range). Medicare averages ~$154 to $160 non-facility. Know your contracted rates.
- Telehealth requires modifier 95 (video) or 93 (audio-only Medicare), with POS 10 or 02. Wrong modifier or POS code equals denial.
- Same-day E/M + psychotherapy uses add-on codes (+90833, +90836, +90838), not standalone 90837. Billing 90837 + 99214 on the same day gets denied.
- Overutilization of 90837 triggers audits. If 80%+ of your psychotherapy claims are 90837, expect scrutiny. Maintain a balanced code distribution.
- Appeal denied claims promptly with specific clinical documentation. Missed appeal deadlines turn recoverable revenue into permanent losses.
Knowing these rules is one thing. Implementing them correctly across every session, every payer, and every provider in your practice, while managing denials, tracking authorizations, staying current on telehealth changes, and catching underpayments, takes time most providers don’t have.
One O Seven RCM specializes in behavioral health medical billing and revenue cycle management. We help psychiatry practices, psychology groups, counseling centers, and solo practitioners:
- Submit clean claims with correct codes, modifiers, and documentation support
- Reduce denial rates through proactive prevention and systematic auditing
- Appeal underpaid and denied claims aggressively
- Stay current on payer policy changes so you don’t have to
- Optimize your entire revenue cycle from credentialing to collections
If you’re spending more time on billing than on patients, that’s a problem we can fix.
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From credentialing and contracting through AR follow-up and denial management, One O Seven RCM manages your entire revenue cycle end-to-end.