How to Bill Medicare 90837 Correctly: The Definitive Therapist Guide (2026)
If you've ever stared at a rejected Medicare claim for a 90837 and thought, "But I did everything right" — you're not alone. CPT code 90837 is one of the highest-volume billing codes in outpatient mental health, and it's also one of the most frequently denied by Medicare. Not because therapists are doing bad clinical work, but because the billing and documentation rules are surprisingly specific, and the margin for error is thin.
This guide breaks down everything you need to know about billing Medicare for 90837 in 2026 — rates, modifiers, documentation requirements, common pitfalls, and exactly what your notes need to say to survive an audit. Whether you're an independent LCSW, an LPC in a group practice, or an LMFT just getting credentialed with Medicare, this is the resource you've been looking for.
What Is CPT Code 90837?
CPT 90837 is the billing code for individual psychotherapy, 60 minutes (53–80 minutes of face-to-face therapy time). It's the most comprehensive of the three core individual psychotherapy codes:
| CPT Code | Session Length | Typical Use | |----------|----------------|-------------| | 90832 | 16–37 minutes | Brief therapy, check-ins | | 90834 | 38–52 minutes | Standard 45-min sessions | | 90837 | 53–80 minutes | Full 60-min therapy sessions |
90837 is the code most therapists want to bill — it pays the most and reflects a full clinical hour. But it's also the code Medicare scrutinizes most heavily, because it requires the most time documentation and carries the highest reimbursement.
Medicare Reimbursement Rates for 90837 in 2026
Medicare sets its reimbursement rates based on the Medicare Physician Fee Schedule (MPFS), which is updated annually. In 2026, the national average Medicare reimbursement for 90837 is approximately $130–$150 per session, though your actual rate depends on your geographic locality (also called the Geographic Practice Cost Index, or GPCI).
For example:
- San Francisco, CA (Locality 5): ~$155–$165
- New York City, NY (Locality 1): ~$148–$158
- Rural Texas: ~$118–$128
💡 Pro tip: Look up your exact rate using the CMS Medicare Physician Fee Schedule Look-Up Tool and filter by your state and specialty. Use specialty code 68 (Clinical Psychologist) or 79 (Licensed Clinical Social Worker) depending on your credential.
Medicare pays 80% of the allowed amount. The patient (or their Medigap plan) is responsible for the remaining 20% coinsurance after their Part B deductible is met.
Who Can Bill Medicare for 90837?
This is where a lot of therapists get tripped up. Medicare has specific credentialing requirements for behavioral health providers. Here's who qualifies:
| Provider Type | Medicare Billing Rights for 90837 | |---|---| | Psychiatrist (MD/DO) | ✅ Yes — can also bill E/M codes | | Psychologist (PhD/PsyD) | ✅ Yes | | Licensed Clinical Social Worker (LCSW) | ✅ Yes — must be independently licensed | | Licensed Professional Counselor (LPC) | ✅ Yes — as of Jan 1, 2024 (SUPPORT Act expansion) | | Licensed Marriage & Family Therapist (LMFT) | ✅ Yes — as of Jan 1, 2024 (SUPPORT Act expansion) | | Licensed Mental Health Counselor (LMHC) | ✅ Yes — as of Jan 1, 2024 | | Master's-Level Counselor (unlicensed) | ❌ No | | Graduate Intern / Supervised Associate | ❌ No (Medicare does not allow incident-to billing for mental health) |
Important note for LPCs, LMFTs, and LMHCs: You became newly eligible for Medicare billing in 2024 under the Consolidated Appropriations Act. However, you must be enrolled in Medicare and credentialed as a participating or non-participating provider before you submit a single claim. Billing before enrollment is grounds for recoupment.
The Correct Modifier Setup for Medicare 90837
Modifiers are one of the leading causes of 90837 claim denials. Here's what you need to know:
Modifier 95 — Telehealth
If the session was conducted via video, you must append modifier 95 (Synchronous Telemedicine Service Rendered via a Real-Time Interactive Audio and Video Telecommunications System) to 90837. As of 2026, Medicare continues to cover telehealth behavioral health services under the flexibilities extended through the Consolidated Appropriations Act, but rules around originating site requirements are evolving — verify current guidance before billing.
Modifier GT
Some Medicare Advantage plans and legacy FFS claims still use modifier GT for telehealth. Check your specific payer's requirements, but for traditional Medicare, 95 is the current standard.
Modifier 59 — Distinct Procedural Service
Use modifier 59 when billing 90837 on the same date as another procedure (e.g., 90837 + 90839 for a crisis intervention). This tells Medicare the services were distinct and not duplicative.
Place of Service (POS) Codes
- POS 02 — Telehealth, patient not in their home
- POS 10 — Telehealth, patient in their home (used most often since 2022)
- POS 11 — Office (in-person)
- POS 53 — Urgent care / community mental health center (for applicable settings)
Getting POS codes wrong is a silent killer for claims. POS 10 vs. POS 02 matters — the reimbursement rate is different.
Documentation Requirements: What Your 90837 Note Must Include
This is the section that determines whether you get paid — and whether you can defend your billing in an audit. Medicare requires that your psychotherapy note demonstrate medical necessity and capture the key elements of a clinical service. Here's what your 90837 progress note must document:
1. Start and End Time (or Total Time)
Medicare is a time-based payer for psychotherapy codes. You must document the actual start and end time of the session, or at minimum the total face-to-face minutes. Without this, you cannot defend billing 90837 vs. 90834.
✅ Correct: "Session began at 2:03 PM and ended at 3:05 PM. Total face-to-face psychotherapy time: 62 minutes." ❌ Incorrect: "60-minute session." (Not sufficient — no actual time anchors)
2. Diagnosis (ICD-10 Code)
Your note must reference a DSM-5 aligned ICD-10-CM diagnosis that supports the need for therapy. Common codes include:
- F32.1 — Major depressive disorder, single episode, moderate
- F41.1 — Generalized anxiety disorder
- F43.10 — Post-traumatic stress disorder, unspecified
- F33.0 — Major depressive disorder, recurrent, mild
The diagnosis must be active and clinically supported. A note that says "anxiety" without a formal ICD-10 code is not compliant.
3. Medical Necessity Statement
Your note must explain why this patient needs therapy at this frequency and intensity. This doesn't have to be a paragraph — it can be clinical and concise — but it must be present.
✅ Example: "Patient continues to present with significant depressive symptoms (PHQ-9 score: 16) impairing occupational and social functioning. Weekly individual therapy is medically necessary to address symptom management and prevent further functional decline."
4. Subjective/Objective Clinical Content
Document what the patient reported, your clinical observations, and the patient's mental status. This is your proof that therapy actually occurred and was clinically meaningful.
5. Interventions Used
Name the therapeutic modality or specific interventions applied during the session.
Examples: "CBT-based cognitive restructuring," "EMDR Phase 3-6 processing," "DBT distress tolerance skills review," "motivational interviewing"
6. Response to Treatment
How did the patient respond during the session? Did they engage? Was there progress, regression, or resistance? This feeds into the ongoing medical necessity narrative.
7. Plan and Next Steps
Document the plan for the next session, any homework assigned, coordination of care, or referrals made.
The 90837 + E/M Code Combination (For Psychiatrists)
If you're a psychiatrist billing both a medication management visit (E/M code) and psychotherapy on the same date, Medicare allows you to bill 90833 (psychotherapy add-on, 16–37 min) or 90836 (38–52 min) or 90838 (53–80 min) as an add-on to the E/M code. You would not bill 90837 standalone in this scenario — you'd bill the E/M code + the psychotherapy add-on code.
This is a common compliance error in psychiatric practices. Billing 90837 standalone when you also billed an E/M on the same day will trigger an edit.
Common Reasons Medicare Denies 90837 Claims
Here's a frank breakdown of why your 90837 claims get rejected or recouped:
| Denial Reason | What's Actually Happening | |---|---| | CO-4 — Modifier required | Missing modifier 95 for telehealth sessions | | CO-50 — Not medically necessary | Your note lacks a clear medical necessity statement | | CO-97 — Included in another code | Billing 90837 alongside an E/M on same date without correct add-on codes | | CO-22 — Coordination of benefits | Medicare is secondary and you didn't submit primary EOB | | CO-167 — Diagnosis not covered | ICD-10 code missing, incorrect, or not linked properly to the service | | PR-119 — Benefit maximum | Patient has hit Medicare outpatient mental health benefit limits (rare but real) | | Timely filing denial | Medicare requires claims within 12 months of the date of service |
Medicare Advantage vs. Traditional Medicare: Know the Difference
This trips up more therapists than almost anything else. Medicare Advantage (Part C) plans are administered by private insurers (Aetna, UnitedHealthcare, Humana, Cigna, etc.) and they do not always follow traditional Medicare rules.
Key differences:
- Prior authorization may be required for 90837 under Medicare Advantage — traditional Medicare does not require PA for outpatient psychotherapy
- Network requirements — Medicare Advantage has narrow networks; you must be contracted with the specific plan
- Documentation standards — Some MA plans have stricter or different requirements than CMS
- Reimbursement rates — MA plans negotiate their own rates; you may be paid more or less than traditional Medicare
Always verify whether a patient has traditional Medicare (Original Medicare) or a Medicare Advantage plan before billing. The card alone doesn't tell you — you need to call the number on the back of the card or check eligibility through your clearinghouse.
How to Handle Medicare Audits for 90837
Medicare RAC (Recovery Audit Contractor) and CERT (Comprehensive Error Rate Testing) auditors frequently target 90837 due to its high reimbursement value. If you're audited, your defense rests entirely on your documentation.
What auditors look for:
- Documented time that justifies 90837 vs. 90834
- A clearly identified ICD-10 diagnosis
- Medical necessity language in every note
- Signatures (credentialed provider name and credentials, dated)
- Evidence that the treating provider is enrolled in Medicare
Best practices for audit defense:
- Keep signed intake documents, treatment plans, and consent forms readily accessible
- Maintain notes in a HIPAA-compliant system with audit trails
- Conduct internal documentation audits quarterly — review 5–10 random charts against Medicare standards
- Respond to Additional Documentation Requests (ADRs) within the stated timeframe (usually 45 days)
90837 Documentation Checklist for Medicare
Before submitting any 90837 claim to Medicare, run through this checklist:
- [ ] Session start and end time (or total minutes) documented
- [ ] Time equals or exceeds 53 minutes of face-to-face psychotherapy
- [ ] Active ICD-10-CM diagnosis linked to the service
- [ ] Medical necessity clearly stated
- [ ] Therapeutic interventions named
- [ ] Patient's response to treatment documented
- [ ] Plan/next steps documented
- [ ] Note signed with full credentials (LCSW, LPC, LMFT, etc.) and date
- [ ] Correct CPT code (90837) and POS code on claim
- [ ] Modifier 95 applied if telehealth
- [ ] Provider is enrolled and credentialed with Medicare
Frequently Asked Questions
1. Can I bill Medicare 90837 for a 55-minute session?
Yes — 90837 applies to sessions that are 53–80 minutes of face-to-face psychotherapy time. A 55-minute session is fully billable under 90837 as long as you document the actual time. You don't have to hit 60 minutes exactly.
2. Can an LPC or LMFT bill Medicare for 90837 now?
Yes. As of January 1, 2024, LPCs, LMFTs, and LMHCs became eligible to enroll in Medicare and bill independently under the Consolidated Appropriations Act of 2023. You must be enrolled before billing — retroactive billing is not permitted.
3. Does Medicare require a treatment plan to bill 90837?
Medicare does not mandate a separate treatment plan document the way Medicaid does, but medical necessity must be established and re-established throughout the chart. A treatment plan is best practice and strongly recommended for audit defense.
4. Can I bill 90837 and 90853 (group therapy) on the same day?
Yes — you can bill both an individual session (90837) and a group session (90853) on the same date of service for the same patient, as long as both services were actually rendered and documented. Use modifier 59 on one of the codes to indicate distinct services.
5. What happens if I accidentally bill 90837 instead of 90834?
If your documentation supports only 38–52 minutes of service, you should have billed 90834. If caught in an audit, Medicare can recoup the difference in reimbursement. You can voluntarily correct this through a claim adjustment within the timely filing window. Voluntary self-disclosure is always better than waiting for an audit finding.
6. Does Medicare cover 90837 via telehealth in 2026?
Yes — as of 2026, Medicare continues to cover 90837 via audio-video telehealth for behavioral health services. The patient may be seen in their home (POS 10). Check current CMS guidance for any updated site-of-service requirements, as these rules have been extended on a rolling basis through Congressional action.
7. How do I find out my exact Medicare reimbursement rate for 90837?
Use the CMS Medicare Physician Fee Schedule Look-Up Tool on cms.gov. Filter by your state, your provider specialty code, and the applicable year. Your MAC (Medicare Administrative Contractor) can also provide locality-specific rates.
The Bottom Line: Accuracy Starts with Your Documentation
Billing Medicare 90837 correctly isn't just about submitting the right code — it's about building a clinical record that tells a complete, defensible story of why this patient needed 60 minutes of therapy and what happened during that session. The code is the easy part. The documentation is where therapists win or lose claims.
Most denials and audit findings come down to three things: missing time documentation, absent medical necessity language, and incomplete or generic notes. Fix those three things, and your 90837 claims will hold up.
Let Mozu Health Handle the Documentation Heavy Lifting
If you're spending more time worrying about whether your notes will survive a Medicare audit than you are focusing on your clients, that's a problem — and it's one that Mozu Health was built to solve.
Mozu Health is an AI-powered clinical documentation platform built specifically for behavioral health providers — therapists, psychiatrists, LPCs, LCSWs, LMFTs, and group practices. Here's what it does for you:
- 🧠 AI-assisted progress notes that automatically capture time, interventions, diagnosis, and medical necessity language in Medicare-compliant format
- 🔒 HIPAA-compliant infrastructure with full audit trails — exactly what Medicare auditors want to see
- 📋 Billing accuracy tools that flag missing modifiers, mismatched POS codes, and documentation gaps before you submit
- 🛡️ Audit defense support — your notes are thorough, timestamped, and structured to withstand scrutiny
- ⚡ Built for the way therapists actually work — fast, intuitive, and designed to get you out of chart notes and back to your clients
Whether you're a solo LCSW just getting credentialed with Medicare or a group practice managing dozens of 90837 claims per week, Mozu Health gives you the documentation infrastructure to bill confidently and compliantly.
👉 Try Mozu Health free at mozuhealth.com — and write your next Medicare-compliant 90837 note in minutes, not an hour.
This article is intended for educational purposes and reflects Medicare billing guidance as of 2026. Always verify current CMS guidelines and consult your Medicare Administrative Contractor (MAC) for the most up-to-date requirements specific to your region and specialty.
