In modern mental healthcare, it’s common for providers—particularly psychiatrists, psychiatric nurse practitioners, and physician assistants—to deliver both psychotherapy and medical management within the same session. While clinically effective, combining these services raises billing complexities. This guide outlines best practices for correctly billing psychotherapy in conjunction with Evaluation and Management (E/M) services.
If your services include both therapy and medication oversight, it’s worth reviewing the proper use of CPT code 90863 for pharmacologic management to ensure clean claims and correct documentation — especially when billing alongside psychotherapy.
Why Integration Matters
Mental health treatment is most effective when medication management is integrated with psychotherapy. However, billing both services accurately requires:
- Proper CPT coding
- Clear documentation
- Awareness of payer-specific rules
Understanding the distinctions and requirements helps maximize reimbursement and avoid compliance issues.
Key CPT Codes for Integrated Sessions
When a provider delivers both E/M and psychotherapy during the same visit, the billing typically includes:
- E/M Code (99212–99215): For medical evaluation and management (e.g., med review, labs, diagnostics)
- Psychotherapy Add-on Code:
- 90833: 30 minutes (with E/M)
- 90836: 45 minutes (with E/M)
- 90838: 60 minutes (with E/M)
These codes must be billed together (e.g., 99214 + 90836), and documentation must clearly justify both services. Many providers face confusion when billing for family sessions, especially regarding the presence or absence of the patient. A helpful overview on the difference between CPT codes 90846 and 90847 for family therapy can clarify when and how to use each code properly.
Documentation Best Practices
To support both codes:
- Separate each service in the note: One section for medical management (E/M), another for psychotherapy
- Document time for each component:
- Total time spent on E/M
- Total time spent on psychotherapy
- Explain the medical necessity for both services
- Avoid duplication: Don’t use the same content to justify both components
Medical Necessity Is Key
You can’t bill both codes just because time was spent. The psychotherapy must be distinct, medically necessary, and clinically appropriate in addition to the medical management. Understanding how payers define “new” vs. “established” patients can prevent billing errors and denials. This article on mental health E/M coding breaks down the rules and how they apply in behavioral health settings.
Examples of psychotherapy content:
- Cognitive Behavioral Therapy (CBT)
- EMDR
- Psychodynamic interventions
- Interpersonal therapy
Modifier Usage and Billing Tips
- No modifier is typically needed when billing E/M + 90833/90836/90838 together
- Submit both codes on the same claim
- Ensure your place of service and payer policies support integrated billing
- Do not use psychotherapy time toward the E/M code (post-2021 changes focus on medical time only)
California Mental Health Billing Tip:
For Medi-Cal and CalAIM, only licensed providers (not interns or associates) can bill certain codes like 90837. Billing under the wrong license type often leads to rejections.
Explore our California Billing Services to avoid these costly mistakes.
Sample Billing Scenario
Scenario: A psychiatric NP conducts a 25-minute medication review (moderate complexity) followed by 30 minutes of CBT.
- Codes: 99214 (E/M moderate complexity) + 90833 (30 minutes psychotherapy)
- Justification: Separate note sections for med management and therapy, with time and content documented
Compliance Considerations
Maintaining compliance is critical. Use audit-ready documentation practices such as:
- Clearly timestamped notes
- Problem-focused documentation for E/M
- Goal-directed therapy notes for Psychotherapy
- Use of standardized templates or EHR flags
Common Errors to Avoid
- Billing a psychotherapy add-on code without an appropriate E/M code
- Using time for psychotherapy to justify E/M code level
- Incomplete documentation of time or content
- Overusing add-on codes without demonstrating the need
Reimbursement Rates (Typical Range)
| CPT Code | National Avg. Reimbursement (Medicare) |
| 99213 | $100 |
| 99214 | $140 |
| 90833 | $75 |
| 90836 | $105 |
| 90838 | $145 |
Rates vary based on region and payer. Always check with your specific insurance contracts.
Insurance & Telehealth Considerations
Many insurers cover both services via telehealth, especially post-pandemic. Key steps:
- Use appropriate modifiers (e.g., 95)
- Use correct POS (place of service) codes
- Verify payers allow both E/M and psychotherapy on the same telehealth claim
Electronic Health Record (EHR) Optimization
To reduce billing errors and streamline documentation, consider integrating EHR tools that:
- Provide time trackers for psychotherapy and E/M separately
- Offer structured templates for note division
- Automatically prompt payer-specific requirements
- Generate audit-ready billing reports
State and Federal Guidelines
Understand your regional guidelines as billing rules can vary. For example:
- Medicare generally allows billing for both services, provided all documentation requirements are met
- Medicaid programs vary significantly between states
- Private insurers may require pre-authorization for one or both services
Use tools such as the CMS Physician Fee Schedule to verify what’s billable in your jurisdiction.
Audits and Risk Mitigation
E/M + psychotherapy combinations are closely scrutinized. To reduce audit risk:
- Keep documentation detailed but concise
- Review payer policies every 6–12 months
- Train staff and clinicians regularly on documentation standards
- Conduct internal audits
Educational Opportunities
Staying up to date is critical. Attend:
- AAPC and AMA coding webinars
- State board workshops
- Online CEU courses for behavioral health billing
Best Practices Summary
- Separate documentation for E/M and psychotherapy
- Accurate coding (9921x + 9083x)
- Clear time logs and medical necessity
- Know your payer’s rules
- Train your team on updates and maintain audit-readiness
Resources and Guidelines
FAQs
1. Can a therapist and psychiatrist bill separately for the same session?
Not typically. Two providers can’t bill at the same time. Split services must be on different dates or times.
2. Is time for psychotherapy included in E/M billing?
No. E/M time and psychotherapy time are counted separately.
3. Can I use psychotherapy codes without E/M?
Yes. If no medical management occurs, bill only psychotherapy (e.g., 90834).
4. Do I need special documentation software?
Not required, but templates that support dual service notes improve clarity and compliance.
5. Are these codes valid for telehealth?
Yes, if allowed by the payer. Always confirm coverage and required modifiers.
6. What should I do if a payer denies my E/M + 90833 claim?
Check that documentation separates both services and supports medical necessity. If all requirements are met, file an appeal with supporting documentation.
7. Can I delegate documentation of psychotherapy to a medical scribe?
Scribes may assist in E/M documentation, but psychotherapy notes must be authored by the clinician delivering the service.
8. Do different states have unique billing requirements?
Yes. Always consult your state Medicaid guidelines and private payer manuals for regional differences.
