CPT 90832, 90834 and 90837 are the codes for individual psychotherapy, and the documented psychotherapy time decides which one you bill: 16 to 37 minutes is 90832 (the 30-minute code), 38 to 52 minutes is 90834 (45 minutes), and 53 minutes or more is 90837 (60 minutes). Under 16 minutes, no psychotherapy code applies. 90791 is the psychiatric diagnostic evaluation used at intake, and 90792 is the same evaluation with medical services. Medicare contractors expect start and stop times or total time in every psychotherapy note, and missing time is one of the most common audit findings for these codes.
For every behavioral health code in one place, see our CPT codes guide for behavioral health. This article goes deeper on the psychotherapy time codes: the thresholds and where they come from, time documentation, E/M add-ons, interactive complexity, crisis and family codes, 2026 telehealth rules, and the edits that deny these codes. Rules below are Medicare rules unless stated otherwise; commercial and Medicaid plans publish their own policies, so check each one.
The short version
- Time picks the code: 16 to 37 minutes is 90832, 38 to 52 is 90834, 53 or more is 90837. Bill the minutes in the note, not the length of the appointment slot.
- Record start and stop times or total psychotherapy minutes in every note. In a 2023 audit, OIG found psychotherapy time undocumented on 60 of 216 sampled Medicare enrollee days.
- With an E/M visit, use add-ons 90833, 90836 or 90838, count only psychotherapy minutes, and choose the E/M level on medical decision making.
- 90791 and 90792 are not reportable with psychotherapy on the same date under NCCI, and Medicare contractor policies expect them once at onset, repeated after a long break or a significant change.
- Crisis codes 90839 and 90840 stand alone. Interactive complexity (90785) is never billed with crisis codes or with an E/M visit alone.
- Medicare telehealth flexibilities run through December 31, 2027, and the in-person visit requirement for mental health telehealth applies after that date.
The time thresholds at a glance
Each code carries a nominal time (30, 45 or 60 minutes) and a range. First Coast billing article A57520 tells providers to "choose the code closest to the actual time," and Palmetto GBA and Noridian publish the same ranges. The boundaries sit just past the midpoints between nominal times (15, 37.5 and 52.5 minutes), the CPT convention that a unit of time is reached once the midpoint is passed. Noridian applies it to family therapy too, listing 26 minutes as the floor for the 50-minute code 90846.
| Code | Description | Time rule | 2026 national non-facility amount* |
|---|---|---|---|
| 90832 | Psychotherapy, 30 minutes with patient | 16 to 37 minutes | $85.84 |
| 90834 | Psychotherapy, 45 minutes with patient | 38 to 52 minutes | $113.90 |
| 90837 | Psychotherapy, 60 minutes with patient | 53 minutes or more | $167.00 |
| +90833 | Psychotherapy with E/M, 30 minutes | 16 to 37 minutes of psychotherapy | $81.50 |
| +90836 | Psychotherapy with E/M, 45 minutes | 38 to 52 minutes of psychotherapy | $103.21 |
| +90838 | Psychotherapy with E/M, 60 minutes | 53 minutes or more of psychotherapy | $136.61 |
| 90791 | Psychiatric diagnostic evaluation | Once per day | $173.35 |
| 90792 | Psychiatric diagnostic evaluation with medical services | Once per day | $202.08 |
| 90839 | Psychotherapy for crisis, first 60 minutes | Covers the first 30 to 74 minutes | $160.32 |
| +90840 | Psychotherapy for crisis, each additional 30 minutes | Add-on to 90839 | $77.16 |
| 90846 | Family psychotherapy without patient, 50 minutes | At least 26 minutes (Noridian) | $105.88 |
| 90847 | Family psychotherapy with patient, 50 minutes | 50-minute code | $109.55 |
| +90785 | Interactive complexity | Add-on only | $14.70 |
*Total non-facility RVUs from the CMS 2026 fee schedule file (October release) times the $33.4009 conversion factor, before geographic adjustment and cost sharing. Medicare pays clinical social workers, marriage and family therapists and mental health counselors 75% of the clinical psychologist amount. A plus sign marks an add-on code.
How to document time so it survives review
A57520 is direct: "Start and stop times or total times must be documented for CPT codes 90832, 90834, and 90837." Either format works; a note with no minutes, or one encounter time that mixes psychotherapy with other services, does not. In a May 2023 nationwide audit, HHS-OIG estimated that of $1 billion Medicare paid for psychotherapy from March 2020 through February 2021, $580 million was improper. On 54 sampled enrollee days the notes had neither start and stop times nor a total; on 6 more, psychotherapy billed with an E/M visit did not show the psychotherapy minutes.
What counts toward the minutes:
- Face-to-face psychotherapy. A57520 says psychotherapy times are for face-to-face services with the patient, and the patient must be present for all or some of the service.
- Family members as informants. The 2026 NCCI Policy Manual says 90832 to 90838 include all psychotherapy provided to a patient with family members as informants, if present, on a single date.
- Not the E/M work. When psychotherapy is added to an E/M visit, the psychotherapy total excludes E/M time (A57520).
- Not the slot. Noridian asks for the actual time spent. A 60-minute appointment where the session ran 48 minutes is 90834.
Illustrative examples (hypothetical sessions):
| Documented in the note | Psychotherapy minutes | Code |
|---|---|---|
| Start 9:00, stop 9:14 | 14 | No psychotherapy code (under 16) |
| Start 9:00, stop 9:38 | 38 | 90834 |
| Total time 53 minutes | 53 | 90837 |
| Medication visit: E/M documented separately, psychotherapy 10:12 to 10:30 | 18 | E/M plus 90833 |
| Medication visit: 40 minutes total, psychotherapy portion not stated | Unknown | E/M only; the add-on is not supported |
Make the minutes a required template field and derive the code from them. On review, the documented time wins over the billed code.
90837 vs 90834: choosing and defending the longer code
The clock decides: 52 minutes is 90834, 53 is 90837. At 2026 national non-facility rates, 90837 pays $167.00 and 90834 pays $113.90, so rounding up is both an overpayment risk and a visible data pattern.
Contractors watch it. LCD L33252 says practitioners with high per-patient utilization compared with peers may be subject to medical necessity review, and CGS ran a service-specific post-payment review of 90832, 90834 and 90837 starting in 2021. A 90837 note should show 53 or more minutes and enough clinical content to explain the length: risk assessment, safety planning, or the specific intervention that took the time.
Two rules apply above an hour. A57520 allows a prolonged service code with 90837 only when the psychotherapy, not performed with an E/M service, lasts 90 minutes or longer with direct patient contact. WPS billing article A57480 adds that sessions longer than 90 minutes are paid only when the record documents the face-to-face time and the medical necessity for the extended time. Prolonged services cannot be reported with the add-on codes 90833, 90836 or 90838.
Intake codes: 90791 and 90792
90791 is the psychiatric diagnostic evaluation; 90792 adds medical services such as examination elements, prescribing and ordering tests (L33252). A57520 lets a physician or non-physician practitioner use 90792 or an E/M code for an evaluation with medical assessment.
LCD L33252 lists what the evaluation should contain:
- Reason for the evaluation or chief complaint, and the referral source if any
- History of present illness, including how long problems have existed
- Past psychiatric history, significant medical history and current medications
- Social and family history
- Mental status exam, and strengths and liabilities
- Diagnostic impression and problem list
- Treatment plan with methods of therapy, anticipated length of treatment and measurable, objective goals
For payment, frequency and same-day rules matter most. L33252 and A57480 say the evaluation is done once at the onset of illness or suspected illness, and may be repeated by the same provider after an extended break (about 6 months), an inpatient psychiatric admission, or a significant change in mental status. The 2026 NCCI Policy Manual says 90791 and 90792 are not separately reportable with individual, group, family, crisis or other psychotherapy on the same date, and E/M codes shall not be reported with either. The Medicare practitioner MUE for each is one unit per day.
Psychotherapy with E/M: 90833, 90836, 90838
Prescribers who provide therapy in a medication visit bill the E/M code plus an add-on. The rules (A57520, A57480, Noridian):
- Both services must be significant and separately identifiable. They may sit in one note, but each has to stand on its own.
- Choose the E/M level on medical decision making. A57480 says time may not be used as the basis of E/M code selection when the psychotherapy add-ons are reported.
- Time the psychotherapy separately. Noridian asks for the time spent on psychotherapy rather than one total that includes the E/M service. The add-on follows the same 16, 38 and 53-minute thresholds.
- No separate diagnosis is required for the E/M and the psychotherapy on the same date (A57480).
Rule 3 is where OIG found errors: one sampled note recorded 60 total minutes but not the psychotherapy portion, so the psychotherapy payment was unallowable.
Interactive complexity: 90785
90785 is an add-on for communication factors that complicate a psychiatric service. L33252 and A57480 require at least one of four factors in the record:
- The need to manage maladaptive communication among participants (high anxiety, high reactivity, repeated questions or disagreement)
- Caregiver emotions or behavior that interfere with carrying out the treatment plan
- Evidence or disclosure of a sentinel event with a mandated report to a third party, and discussion of it with the patient and other participants
- Use of play equipment, physical devices, an interpreter or a translator to overcome barriers to interaction
Name the factor, describe the adaptation and, with a time-based code, state the time spent on it (A57520), which lists 90785 with 90791, 90792, 90832 to 90838 and group code 90853. Do not report it with the crisis codes, with an E/M visit when no psychotherapy is reported (A57480), or when the patient cannot communicate by any means (A57520).
Crisis psychotherapy: 90839 and 90840
CMS describes psychotherapy for crisis as an urgent assessment and history of a crisis state, a mental status exam and a disposition, for patients in high distress with life-threatening, complex problems that require immediate attention. 90839 is the first 60 minutes; an HHS ASPE report describes it as covering the first 30 to 74 minutes on a date, with 90840 for each additional 30 minutes.
- Time can be split. A57520 counts total face-to-face time on the date even if it is not continuous, and the clinician cannot serve another patient during that time.
- Stand-alone codes. CMS says not to bill them with 90791, 90792, 90785 to 90899 or 90832 to 90838.
- Once per day. Noridian says 90839 is billed only once a day, and its Medicare MUE is one unit.
- Site of service. HCPCS G0017 and G0018 apply in places of service where the non-facility rate applies, other than the office, and CMS pays them at 150% of the non-facility amount.
Document the crisis, mental status exam, safety interventions, resources mobilized, disposition and total minutes.
Family psychotherapy: 90846 and 90847
90846 is family psychotherapy without the patient present and 90847 is conjoint therapy with the patient present; the NCCI manual describes both as 50 minutes. Medicare covers family psychotherapy when the primary purpose is treatment of the patient's condition (L33252), and the CMS fee schedule file flags 90846 with status R, restricted coverage. Notes should show themes, interventions and responses. Under NCCI, family psychotherapy may be reported with individual psychotherapy on the same date only as a separate and distinct service in a separate time interval. The Medicare MUE is one unit per day for each.
Telehealth rules for psychotherapy in 2026
Under Medicare, the psychotherapy codes are on the telehealth list, and the patient's home is a permitted originating site for mental health and SUD treatment with no geographic restrictions. The CMS Telehealth FAQ (updated February 26, 2026) and MLN booklets set the claim details:
- Place of service. POS 10 when the patient is at home, POS 02 when the patient is elsewhere. Home telehealth is paid at the non-facility rate.
- Audio-only. Allowed for behavioral health with the patient at home when the practitioner can offer video but the patient cannot use it or does not consent to it. Novitas lists modifier 93 for audio-only services and FQ as an option for RHCs and FQHCs.
- In-person requirement. The requirement for an in-person visit within 6 months before the first mental health telehealth service applies after December 31, 2027. CMS says patients who began home mental health telehealth before January 1, 2028 are treated as established and will need at least one in-person visit every 12 months after that date.
- Other payers. Medicaid and commercial plans set their own modifier, POS and audio-only rules.
Record modality (video or audio-only), patient location and start and stop times in every telehealth note.
Denials and edits that hit psychotherapy codes
| Denial | Typical psychotherapy cause | Fix |
|---|---|---|
| CO-151 (frequency not supported) | Units above the Medicare practitioner MUE: 2 per day for each of 90832 to 90838, 1 for 90791, 90792, 90839, 90846 and 90847. Also frequency the record does not explain. | Separate sessions need separate times; document why frequency rose |
| CO-236 or CO-97 (code pair or bundled) | 90791 with psychotherapy on the same date; crisis codes with other psychotherapy; family and individual therapy without a separate interval; therapy billed inside a program per diem | Fix scheduling and charge capture; bill both only when rules allow |
| CO-11 or CO-167 (diagnosis) | Diagnosis outside the covered list in the billing article, or an organic diagnosis billed where a mental health diagnosis was established | Bill the documented mental health diagnosis; check covered lists |
| CO-50 (medical necessity) | Notes without symptoms, functional impact, specific interventions or progress; stale treatment plan | Appeal against the payer's criteria with the record |
| CO-4 or CO-16 (modifier or claim data) | Telehealth modifier or POS that does not match the payer's policy or the patient's location | Corrected claim |
The Medicare Claims Processing Manual says MUE failures get CARC 151 with group code CO and deny the entire line, and as a coding denial, an Advance Beneficiary Notice does not shift liability to the patient. For edits with adjudication indicator 3, which the psychotherapy codes carry, the contractor reviews records on reopening or redetermination. For the full code-by-code playbook, see our behavioral health denial codes guide, and for necessity appeals, our CO-50 appeal guide.
Many psychotherapy losses arrive later, as recoupments after review. L33252 expects each session note to show a psychiatric illness or symptoms that alter baseline functioning, a detailed summary of interventions, and the patient's participation, response and progress; it calls statements such as "supportive psychotherapy given" inadequate and expects treatment plans updated generally at least every three months. OIG found incomplete or missing treatment plans on 43 of 216 sampled enrollee days. In IOP and PHP, the NCCI manual allows more than one psychotherapy unit per day in a Medicare partial hospitalization or intensive outpatient setting; our IOP and PHP billing guide covers program rules.
Pre-bill checklist for psychotherapy notes
- Start and stop times or total psychotherapy minutes are recorded, and the code matches the range.
- With an E/M visit: psychotherapy minutes are separate from E/M work, and the E/M level rests on medical decision making.
- The patient was present for all or part of the session; family participants are named.
- The note shows symptoms and their effect on functioning, specific interventions, the patient's response and progress toward goals.
- The treatment plan is current, with measurable goals, frequency and expected duration.
- Any 90785 names the communication factor, the adaptation and the time.
- No 90791, 90792 or 90785 on a crisis-code date; no 90791 on a psychotherapy date, and any repeat 90791 has a documented reason.
- Telehealth notes record modality, patient location and the POS and modifier the payer requires.
- The claim diagnosis is the documented condition treated; the note is signed with credentials.
How Adentris helps
Every item on that checklist can be verified from the chart before the claim goes out. Autonomous Coding codes every claim against the chart, and Adentris reviews every active chart, not a sample, against payer and regulatory rules, including medical necessity, payer documentation rules and treatment plan and signature timing. Each finding cites the rule that fired, and the correction is drafted for staff to approve. It works on top of any EHR, connecting through its API or FHIR, HL7 feeds, an API our agents build where none exists, or the AI Web Agent, usually with no IT project on your side, and is typically live in about 30 days. To see it on your own charts, book a 30-minute call with our team.
Related reading
- CPT Codes for Behavioral Health and Psychotherapy: A 2026 Guide
- Denial Codes in Behavioral Health: The CARCs That Cost BH and SUD Programs the Most
- CO-50 Denials in Behavioral Health: Why Medical Necessity Gets Denied and How to Appeal
Sources
- First Coast billing article A57520 and LCD L33252
- WPS billing article A57480
- Noridian JF Part B: Mental Health
- Palmetto GBA JM Part B: Psychotherapy Services
- CGS: Post-payment review of psychotherapy codes (2021)
- 2026 Medicare NCCI Policy Manual, Chapter XI
- CMS: Medicare NCCI Medically Unlikely Edits (practitioner table effective October 1, 2026)
- Medicare Claims Processing Manual, Chapter 23
- CMS: 2026 PFS relative value file, RVU26D
- CMS: Psychotherapy for Crisis
- HHS ASPE: Outpatient Behavioral Health Providers in Crisis Services (2025)
- CMS: Telehealth FAQ, updated February 26, 2026
- CMS MLN: Telehealth and Remote Monitoring (MLN901705) and Medicare and Mental Health Coverage (MLN1986542)
- Novitas Solutions: Telehealth service modifiers
- HHS-OIG report A-09-21-03021 on psychotherapy payments (May 2023)
- X12: Claim Adjustment Reason Codes
Frequently asked questions
How many minutes is CPT 90837?
90837 is described as 60 minutes of psychotherapy, but Medicare contractors accept it for 53 minutes or more of documented psychotherapy time. A 52-minute session is 90834. Record start and stop times or the total minutes in the note.
What is the difference between 90834 and 90837?
Documented time. 90834 covers 38 to 52 minutes of individual psychotherapy and 90837 covers 53 minutes or more. At 2026 national Medicare non-facility rates, 90834 pays $113.90 and 90837 pays $167.00 before geographic adjustment, so payers watch how often 90837 is billed.
Can you bill 90832 for a session under 16 minutes?
No. Medicare billing articles say not to report psychotherapy of less than 16 minutes. 90832 starts at 16 minutes and runs to 37.
Can 90791 and 90837 be billed on the same day?
Not under Medicare's NCCI policy: 90791 and 90792 are not separately reportable with any psychotherapy on the same date, because psychotherapy includes continuing psychiatric evaluation. Other payers may apply the same edit.
Do I need start and stop times for psychotherapy?
You need either start and stop times or total psychotherapy time; billing article A57520 accepts both. With an E/M visit, show psychotherapy minutes separately from the E/M work.
What is the in-person requirement for Medicare telehealth therapy?
By statute, an in-person visit is required within 6 months before the first mental health telehealth service, and CMS says this applies after December 31, 2027. Patients who start home mental health telehealth before January 1, 2028 are treated as established and will need an in-person visit at least every 12 months after that date.