90837 claims need 53 minutes written in the note
Federal auditors found the psychotherapy time undocumented in 60 of 216 sampled visits. Medicare's 2026 national rate for a 90837 is $125.25 for therapists.
Head of Growth and Operations, JotPsych
Your 90837 note describes the session but gives no start time, stop time, or total minutes. Write the psychotherapy minutes in every note, as a start and stop time or a total.
Under CPT, 90837 covers 53 minutes of psychotherapy or more, per the time rules quoted in federal audit report A-09-21-03021 (2023). A note without the minutes doesn't support the code.
Look for the psychotherapy minutes in your recent 90837 notes. For Medicare claims in Florida, Puerto Rico, and the U.S. Virgin Islands, the contractor First Coast requires the minutes for every 90837. Elsewhere, check your own Medicare contractor's billing rules.
What federal auditors found
Federal auditors sampled 216 Medicare psychotherapy visits from March 2020 to February 2021, and 94 of them were billed as 90837, more than any other code. Only 84 met Medicare's rules.
Missing time led the findings. In 60 of the 216, the note didn't document the psychotherapy time. In 54 of those, the note gave no start and stop time and no total. The auditors estimated $580 million in improper payments, of the $1 billion Medicare paid for psychotherapy in that year.
Counts from Appendix H of federal audit report A-09-21-03021 (2023), which lists six Medicare requirements and two guidance items. Check your recent 90837 notes for the psychotherapy minutes, a complete treatment plan, and a record that psychotherapy took place.
What to put in each 90837 note
- Write your start and stop time, or your total minutes. Auditors counted either one.
- Count only your psychotherapy time. Minutes you spend on other tasks in the visit don't count toward the 53 minutes.
- Bill a shorter code when you have fewer minutes. Sessions of 38 to 52 minutes bill as 90834, and 16 to 37 minutes as 90832, so your minutes pick the code even when the visit filled the hour.
What 90837 pays by payer
Medicare's 2026 national rate for a 90837 is $167.00 for psychologists. If you're a therapist, meaning a clinical social worker, mental health counselor, or marriage and family therapist, Medicare sets your rate at 75% of that. PayerPrice's national averages for 90837 run from $138.60 at UnitedHealthcare to $180.84 at Cigna.
Medicare's figure is its 2026 national rate for therapists; the commercial figures are PayerPrice national averages, August 2026, one per payer with no split by clinician type. Compare your contracted 90837 rate from each payer with that payer's bar.
At your next contract renewal, ask each payer whose average tops your contracted 90837 rate for at least that average.
In JotPsych's Session Details, set each 90837 note's session time to the psychotherapy's start and end before you sign.
Book 15 minutes- Centers for Medicare & Medicaid Services (CMS), Physician Fee Schedule Relative Value Files, RVU25A (released 2025-01-10) and RVU26A (released 2025-12-29): national non-facility rates.
- First Coast Service Options, Billing and Coding: Psychiatric Diagnostic Evaluation and Psychotherapy Services (A57520), version 43, revision effective January 1, 2025, read October 2, 2026.
- CMS, Medicare Learning Network, Medicare & Mental Health Coverage, booklet MLN1986542, March 2026, pages 13 to 24: physicians and psychologists paid 100% of the fee schedule amount, nurse practitioners 85%, and clinical social workers, marriage and family therapists, and mental health counselors 75% of the psychologist amount.
- U.S. Department of Health and Human Services, Office of Inspector General (OIG), Medicare Improperly Paid Providers for Some Psychotherapy Services, Including Those Provided via Telehealth, During the First Year of the COVID-19 Public Health Emergency, report A-09-21-03021, May 2, 2023.
- PayerPrice, CPT 90837 Fee Schedule by Payer: national payer-file averages, verified August 2026.