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90837 Billing Guide: Psychotherapy, 60 Minutes

September 17, 2026 · 3 min read

What Is CPT 90837?

CPT 90837 is used to report individual psychotherapy services with the patient for approximately 60 minutes.

For Medicare, CMS currently describes 90837 as psychotherapy for 60 minutes with the patient. CMS also identifies 90832, 90834 and 90837 as psychotherapy codes without medical management.

Because 90837 is a time-based psychotherapy code, the medical record needs to support the service and the applicable time requirements.

When Is 90837 Used?

90837 may be appropriate when the provider furnishes an individual psychotherapy service that meets the applicable requirements for the code.

The service should reflect the actual service provided and the applicable payer's billing requirements.

A provider should not select 90837 simply because the appointment was scheduled for an hour.

The documentation needs to support the reported service.

90837 vs 90834

One of the most common questions is:

What's the difference between 90834 and 90837?

CMS's current Medicare billing guidance identifies:

  • 90834: Psychotherapy, 45 minutes
  • 90837: Psychotherapy, 60 minutes

CMS's current Medicare contractor guidance describes psychotherapy time ranges of approximately 38–52 minutes for 90834 and 53 minutes or more for 90837.

Payer-specific requirements should always be checked before applying a particular time threshold.

Documentation for 90837

The medical record should support the service that was actually provided.

Depending on the payer and applicable requirements, documentation may need to establish:

  • Medical necessity
  • Service performed
  • Date of service
  • Patient participation
  • Duration/time
  • Clinical content
  • Assessment/intervention
  • Treatment plan or progress
  • Provider identity

CMS guidance for psychotherapy states that start/stop times or total time should be documented for 90832, 90834 and 90837.

Common 90837 Billing Problems

Insufficient Time Documentation

If the record doesn't support the reported time, the claim can become vulnerable to review or denial.

Medical Necessity Issues

The documentation should support why psychotherapy was medically necessary under the applicable coverage policy.

Incorrect Code Selection

The billed code should correspond to the service and time actually documented.

Payer-Specific Requirements

Commercial plans may have requirements that differ from Medicare.

Can 90837 Be Billed With an E/M Service?

90837 is a psychotherapy code without medical management.

When psychotherapy is performed together with an E/M service, different add-on codes may apply, such as 90838, depending on the circumstances and provider qualifications.

CMS identifies 90833, 90836 and 90838 as psychotherapy codes performed with an E/M service and describes them as add-on codes.

90837 Telehealth Billing

Telehealth billing requirements vary by payer.

For Medicare professional billing, CMS currently identifies:

POS 02: Telehealth provided other than in the patient's home.

POS 10: Telehealth provided in the patient's home.

CMS's current telehealth guidance confirms these POS definitions.

Do not assume that a commercial payer uses exactly the same telehealth billing requirements as Medicare.

90837 Billing Checklist

Before submitting a 90837 claim, a billing team should review:

  • Correct patient
  • Correct provider
  • Correct date of service
  • Correct payer
  • Correct diagnosis
  • Correct CPT
  • Appropriate modifier if required
  • Appropriate place of service
  • Documentation supporting time
  • Documentation supporting medical necessity
  • Authorization requirements where applicable

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