NoteScreen blog

90834 vs 90837: What Your Documentation Actually Needs to Say

For solo and small-group behavioral health clinicians doing their own billing

You probably already know that 90834 and 90837 both describe individual psychotherapy sessions. You know 90834 is the 45-minute code and 90837 is the 60-minute code. What clinicians often do not know — until a payer sends back a denial — is exactly what documentation each code requires, and why 90837 draws a disproportionate share of audit attention.

This article walks through the time thresholds, the midpoint rule that trips people up, and what a defensible note looks like for each code. Nothing here is billing or legal advice. Your payer contracts are the final word.

The Time Thresholds and the Midpoint Rule

Both codes belong to the timed psychotherapy family. The underlying principle is the midpoint rule: a timed code is reportable when the documented time reaches the midpoint between that code’s floor and the next tier’s floor.

In plain numbers:

90834 covers sessions documented at 38–52 minutes of face-to-face psychotherapy time. The midpoint logic: 38 minutes is the midpoint between 90832’s nominal time (30 min) and 90834’s nominal time (45 min) — meaning the 90832 tier itself covers 16–37 minutes, and 90834 begins at 38. You can report 90834 through 52 minutes before crossing into 90837 territory.
90837 covers sessions documented at 53 minutes or more. That 53-minute floor comes from the midpoint between 45 and 60 minutes (52.5, rounded up to a practical threshold of 53).

The practical takeaway: if you are billing 90837, your documentation must support at least 53 minutes of face-to-face psychotherapy time — not “approximately an hour” and not “60 minutes” if the session actually ran 50.

Common mistake

Running a 55-minute session, writing “1-hour session,” and billing 90837. That is fine as long as you actually spent 53+ minutes in psychotherapy. The problem comes when clinicians round up to 60 minutes on a session that genuinely ended at 48 minutes. That gap is what auditors are looking for.

What Documentation Each Code Requires

For 90834

For a 45-minute session code, payers generally want to see:

Start and stop times (or total face-to-face time), clearly stated in the note — not just implied by the appointment slot in your EHR
Presenting problem and clinical status at the session
Interventions used (what you actually did therapeutically, not just "supportive therapy")
Response to treatment and progress toward goals
Plan for next session
A medical necessity statement appropriate to the diagnosis being treated

Many EHRs auto-populate a time field from the scheduled appointment length. That is not the same as documented start and stop times. If your SimplePractice note says “50 minutes” because that is how long your appointments are scheduled, but the actual session ended at 43 minutes, the auto-populated time is inaccurate.

For 90837

Everything from 90834 applies, plus two additional documentation obligations that payers increasingly scrutinize:

Why 60 minutes was clinically necessary. Some payers — especially Medicaid plans and certain commercial payers — explicitly require a statement explaining why the longer session was medically indicated rather than simply the clinician’s scheduling preference. Think one to two sentences: “Extended session warranted by active suicidal ideation requiring safety planning and crisis intervention, in addition to standard individual psychotherapy.”
More granular time accounting. A note that says “60-minute session” with no further time detail is thin. A note that says “Session began at 2:00 PM and concluded at 3:05 PM; 65 minutes of individual psychotherapy” is much harder to dispute.

Why 90837 Draws More Audit Scrutiny

The short answer: money and frequency.

90837 reimburses significantly more than 90834 across virtually every payer. That differential is large enough that a pattern of billing 90837 for the majority of sessions — without corresponding documentation — is a recognized audit trigger.

Here is what payers and their audit vendors look for:

High 90837 utilization rate. A clinician billing 90837 for 80–90% of all sessions is an outlier. Most clinicians have a mix. If your panel consists of clients who genuinely need 60-minute sessions, that is defensible — but the documentation has to show it.
Template-pasted time. If every note says “60-minute individual psychotherapy session” with identical language and no variation, it looks like a template fill-in rather than a real account of each session.
Missing or vague time documentation. “Approx. 1 hour” is not the same as documented start and stop times.
No medical necessity language for longer session. Especially for Medicaid.

None of this means you cannot bill 90837 appropriately and frequently. Many client populations genuinely need and benefit from 60-minute sessions. The documentation just has to hold up to a second reader who was not in the room.

How to Document Defensibly

Here is a structure that works for either code. Adapt it to your EHR’s template.

Time: Session began at [time], concluded at [time]. Total face-to-face psychotherapy time: [X] minutes.

Clinical status: [Brief statement of presenting concerns and current severity — link to diagnosis.]

Medical necessity: [Why this patient, at this frequency, at this session length — tied to diagnosis and treatment goals.]

Interventions:[What you actually did. Specific modalities, techniques, focus areas — not just “CBT” or “supportive.”]

Response and progress: [Observable response during session; progress or regression toward treatment plan goals.]

Plan: [Next session focus, any between-session tasks, medication coordination if applicable, any safety considerations.]

For 90837 specifically, add one sentence in the medical necessity or plan section addressing why the longer session was clinically indicated for this particular visit.

A Note on "Start/Stop" vs. "Total Time"

Some payers accept total time (“53 minutes of individual psychotherapy”); others want explicit start and stop times (“2:00 PM to 2:55 PM”). When in doubt, document both. It takes five seconds and eliminates the ambiguity entirely.

If your EHR’s note template only has a total-time field, add a sentence in your note body: “Session concluded at [time].” That is enough.

The Bigger Picture

A denial for 90837 is rarely random. It is usually because the documentation is thin relative to what the code implies. A payer reviewer reading your note should be able to reconstruct that the session was 53+ minutes of genuine individual psychotherapy, that it was medically necessary at that length, and that meaningful clinical work occurred.

If your note would pass that test, you are in good shape. If it would not — if a reviewer might reasonably wonder whether the session was really 60 minutes, or why 60 minutes rather than 45 — that is the gap worth closing.

Check Your Next Note Before You Submit

NoteScreen’s free documentation check runs your note against the requirements for 90834, 90837, and a growing set of other behavioral health codes. Paste your de-identified note, enter the code, and get a plain-language readout of what the documentation supports — and what is missing.

No signup required to try it. One caught denial pays for a year of the Solo plan.

Run your note through NoteScreen free — 10 checks/month, no credit card.

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NoteScreen is a documentation support tool, not a billing guarantee. You retain sole responsibility for what you submit. No payment is guaranteed. This article is informational only and does not constitute billing or legal advice. Always verify coding requirements against current payer policies and CPT guidelines.