Most of the 90837 problems we see on billing teams are not coding mistakes. They are documentation gaps: a 60-minute appointment with no recorded end time, a note template that prints "60 min" by default, or time that includes paperwork after the patient left. Those are the claims payers ask about later.
Educational content from the AiMediCoder editorial team. It is not coding, billing, clinical or legal advice. Code definitions and payer rules change; confirm the current CPT definitions, CMS guidance and each payer's written policy before you bill. Clinic names in examples are fictional.
The time ranges, side by side
CPT psychotherapy codes use a time rule: you report the code whose time is closest to the actual time spent, using defined ranges. Medicare contractor guidance repeats these ranges. [1]
| Code | Nominal time | Report when documented time is | Typical use |
|---|---|---|---|
| 90832 | 30 min | 16–37 minutes | Short sessions, check-ins |
| 90834 | 45 min | 38–52 minutes | Standard outpatient session |
| 90837 | 60 min | 53 minutes or more | Extended session |
| — | — | Under 16 minutes | Not reported as psychotherapy |
A common question is whether a 52-minute session can "round up". It can't. 52 minutes is 90834. 53 minutes is 90837. The line is that specific.
What counts as psychotherapy time
- Counts: time spent in psychotherapy with the patient and/or family member, with the patient present for all or part of the service.
- Does not count: writing the note after the session, scheduling, waiting-room time, or a separately billed E/M portion.
- Telehealth: the same time rule applies; the place of service and modifiers change, not the time ranges. See our POS 10 vs 02 and modifier 95 guide.
What the session note should show for 90837
CMS's behavioral health documentation fact sheet is clear that the record must support the service billed. [2] For a time-based code, that means:
- Start and stop times, or total psychotherapy time stated as a number of minutes. Some Medicare contractors and payers specifically expect start and stop times.
- The type of therapy and what was worked on in the session.
- The patient's response and the plan going forward.
- The rendering provider's signature and credentials.
If the note template auto-fills the time, ask the clinician to confirm actual time. A default value that matches every session is one of the first things an auditor notices.
Why payers question 90837
Some payers review 90837 more closely than 90834, and some ask for medical necessity for longer sessions or require authorization after a set number of visits. These are payer policies, not CPT rules, and they vary by plan. What to do:
- Keep a short list, per client account, of which payers have 90837-specific policies and what they ask for.
- When a clinician bills 90837 for almost every session, review a sample of notes for time and rationale before the payer does.
- Do not switch codes to avoid review. Bill what was done and documented.
Add-on codes worth knowing
| Code | What it's for |
|---|---|
| 90833 / 90836 / 90838 | Psychotherapy added to an E/M visit on the same day (time ranges mirror 90832 / 90834 / 90837) |
| 90785 | Interactive complexity, when specific communication factors complicate the session |
| 90839 / 90840 | Psychotherapy for crisis (first 60 minutes / each additional 30 minutes) |
A quick worked example (fictional)
At "Maple Street Counseling", a therapist's note reads 2:00 pm to 2:50 pm. The claim was set to 90837 because the appointment slot was an hour. A pre-submission check catches the mismatch: 50 minutes is 90834. The biller routes it back to the clinician, who confirms the times, and the claim goes out as 90834. No denial, no later recoupment, and a note for the clinic about the template.
Checklist before you release 90834 or 90837 claims
- Documented time is present and falls in the billed code's range.
- Time excludes documentation and any separately billed E/M time.
- Telehealth sessions have the place of service and modifier the payer expects.
- The payer's 90837 policy (authorization or review) has been checked for this plan.
- Clinicians with unusually high 90837 use have had a sample of notes reviewed.
For a broader overview including 90832, see our psychotherapy CPT codes guide. When 90837 claims still come back denied, our CARC denial code guide explains what each code is telling you.
Frequently asked questions
How many minutes is 90834 vs 90837?
Under CPT time guidance, 90834 is reported for 38 to 52 minutes of psychotherapy with the patient, and 90837 for 53 minutes or more. Below 16 minutes, a psychotherapy code is not reported.
Can I bill 90837 for a 50-minute session?
No. A 50-minute session falls in the 38 to 52 minute range, which points to 90834. 90837 starts at 53 minutes of documented psychotherapy time.
Do I need start and stop times in the note?
CPT counts time, but it does not dictate the format. Many payers and auditors expect start and stop times, or at least total psychotherapy time. Check the payer's policy; recording start and stop times is the safest habit.
Does 90837 need prior authorization?
Some payers require authorization or apply extra review to 90837, and many do not. There is no single rule. Check the plan's current policy for the member and date of service.
Which code do I use if therapy is done with an E/M visit?
When psychotherapy is provided on the same day as an E/M service by the same provider, the add-on codes 90833, 90836 and 90838 are used with the E/M code instead of 90832, 90834 or 90837.
Sources
- CMS Medicare Coverage Database — Psychiatric codes billing and coding article
- CMS — Documentation Matters: Behavioral Health fact sheet
Last reviewed 24 October 2026.
