1. Incident-To Billing & Supervision Updates
Incident-to billing allows qualified auxiliary personnel, such as Licensed Professional Counselors (LPCs) and Licensed Marriage and Family Therapists (LMFTs), to provide services that are billed under a supervising physician or Non-Physician Practitioner (NPP), including Nurse Practitioners (NPs) and Physician Assistants (PAs).
2025 Update: What’s New?
Under the latest CMS Final Rule:
- General supervision is now permitted for behavioral health services furnished incident-to.
This means the supervising provider does not need to be physically present during service delivery but must remain available for consultation.
Key Requirements:
- The supervising clinician must initiate the patient’s care.
- Documentation must connect the supervising provider and the auxiliary staff.
The physician or NPP must record their oversight and involvement in the patient’s care.
2. Medical Documentation Essentials
Proper documentation is the backbone of compliant incident-to billing. To meet Medicare standards, your medical records should include:
- Co-signatures and credentials of both the rendering and supervising providers.
- A clear note of the supervising provider’s involvement in care.
- Reference to previous encounters to show continuity of care.
Incomplete or inaccurate records could result in claim denials or audits.
3. CPT Code and Modifier Usage
Psychiatric services use time-based Current Procedural Terminology (CPT) codes to reflect the duration and type of therapy:
| CPT Code | Session Duration |
| 90832 | 16–37 minutes (brief therapy) |
| 90834 | 38–52 minutes (standard session) |
| 90837 | 53+ minutes (extended session) |
Modifiers are used to indicate special circumstances:
- 95 Modifier – Used for synchronous telehealth services
- GT Modifier – Telemedicine delivered through interactive audio and video systems
Important: Always verify if payers require specific modifiers for teletherapy. Some local or commercial plans may have unique requirements.
4. HIPAA-Compliant Psychotherapy Notes
Psychotherapy notes are treated differently under HIPAA, with stricter protections than standard medical documentation.
Requirements:
- Must be stored separately from the general medical record.
- Require written patient authorization before being shared—even for treatment purposes.
Exceptions (when authorization isn’t required):
- Reporting abuse or neglect as legally mandated.
- Addressing immediate threats, such as suicide risks.
- Compliance with court orders.
These notes are primarily intended for the therapist’s use and typically aren’t used for billing unless under review or dispute.
5. Key Elements for Documentation
Each therapy session must include the following to support medical necessity and meet compliance standards:
- Date of service, along with provider’s name and credentials
- Patient history and context of the session
- Observations and therapy techniques applied
- Current diagnosis and clinical rationale
- Medication management, if applicable
- Treatment goals and progress tracking
- Any E/M components, if psychotherapy is combined with evaluation
Well-documented notes help minimize denials and ensure continuity of care.
6. Common Claim Denials & How to Prevent Them
| Common Issue | Prevention Tip |
| Incomplete Documentation | Always include duration, diagnosis, and session outcome. |
| Incorrect CPT Codes | Match the therapy duration with the proper code. |
| Supervision Not Properly Noted | Add the supervising provider’s name and role in the chart. |
| Telehealth Modifier Missing | Use modifiers like 95 or GT when billing remotely. |
| Insurance Verification Issues | Recheck patient eligibility and benefits before sessions. |
| Late Filing of Claims | Follow each payer’s filing deadlines strictly. |
Conclusion
Psychiatric billing in 2025 requires attention to detail, updated knowledge, and consistent compliance. From the revised supervision requirements in incident-to billing to HIPAA safeguards for psychotherapy notes, mental health professionals must stay ahead of regulatory changes to ensure accurate billing and optimized reimbursements.
That’s where I-conic Solutions comes in. With expert guidance, in-depth coding audits, and end-to-end billing services tailored for mental health providers, we help you navigate the complexities—so you can focus more on your patients and less on paperwork.
Need help with psychiatric billing compliance?
Connect with I-conic Solutions and experience billing that works as hard as you do.
