CPT Code 90837: Psychotherapy, 60 Minutes with Patient

CPT code 90837 reports individual psychotherapy lasting 53 minutes or more. It belongs to the psychiatry/psychotherapy category — not the E/M family — and carries no MDM requirement whatsoever. 

Code selection depends entirely on actual psychotherapy duration, and the 53-minute threshold is strict. A 52-minute session is 90834; a 53-minute session is 90837. That single minute separates a ~$114 claim from a ~$167 claim under Medicare.

The financial stakes explain why payers watch 90837 closely. OIG audited one provider and found 111 of 120 psychotherapy claims noncompliant — estimating $3.3 million in overpayments. 

A separate 2025 settlement targeted telehealth psychotherapy where billed duration exceeded the time actually spent. 

For 90837, the highest audit risk is not clinical complexity. It is whether the record proves 53+ minutes of real psychotherapy actually happened.

What does CPT code 90837 cover?

The essential reference facts for 90837 billing.

Detail	CPT 90837
Description	Psychotherapy, 60 minutes with patient
Category	Psychiatry — Psychotherapy Services
Patient type	N/A (no new/established distinction)
MDM level	N/A (not an E/M code)
Time	53+ minutes of psychotherapy
Common modifiers	95, 93, 90785 (add-on)
Medicare rate	~$167.00 non-facility / ~$135.27 facility (2026)
Commonly compared with	CPT 90834

Unlike E/M codes, 90837 does not distinguish between new and established patients, and there is no problems/data/risk calculation. 

The entire code selection question is whether the provider delivered at least 53 minutes of qualifying psychotherapy — not charting, not scheduling, not medication management, not pre-session prep.

When should you use CPT 90837?

The selection decision for 90837 is simpler than E/M codes but demands precise timekeeping.

Use CPT 90837 when

• The provider delivers individual psychotherapy (CBT, EMDR, psychodynamic, supportive, behavioral — any recognized modality)
• Actual psychotherapy time reaches 53 minutes or more
• The provider is not simultaneously performing a separately reportable E/M service (if they are, use the E/M + 90838 add-on structure instead)
• The service is medically necessary and connected to a psychiatric/behavioral diagnosis

Consider a clinical psychologist providing 58 minutes of individual CBT to a patient with PTSD. The note documents trauma-related avoidance symptoms, cognitive restructuring and exposure-planning interventions, the patient’s therapeutic response, and progress toward treatment goals. With 58 minutes of actual psychotherapy, 90837 is appropriate.

When not to use it

• Psychotherapy lasted 38-52 minutes — use 90834
• The service was actually group psychotherapy — use 90853
• The session qualifies as crisis psychotherapy — use 90839/90840
• Time included charting, scheduling, or administrative work rather than therapeutic interaction
• The encounter was a psychiatric diagnostic evaluation, not psychotherapy — use 90791 or 90792
• The same practitioner also performed E/M/medication management — use the appropriate E/M code + 90838 (not standalone 90837)

How is CPT 90837 selected?

Unlike E/M codes with their MDM-or-time pathways, 90837 has only one selection criterion — actual psychotherapy duration.

Time thresholds

The CMS psychotherapy coding guidance applies strict time ranges across the psychotherapy family.

Code	Psychotherapy time
90832	16-37 minutes
90834	38-52 minutes
90837	53 minutes or more

The descriptor says “60 minutes,” but the actual billing threshold is 53.

A 53-minute session correctly supports 90837. A 52-minute session does not — that single minute changes the code and drops reimbursement by roughly $53.

What counts toward the 53 minutes

Only qualifying psychotherapy time applies — the therapeutic interaction itself.

• Direct therapeutic communication with the patient
• Psychotherapeutic interventions (CBT, EMDR, behavioral activation, psychodynamic work, supportive therapy, trauma processing)
• Therapeutic work involving a family member participating as an informant in the patient’s individual treatment

What does NOT count

90837 time is narrower than E/M time. Do not inflate the clock with non-therapeutic activity.

• Pre-session chart review
• Post-session documentation
• Separate psychological testing
• Scheduling and administrative tasks
• Care coordination outside the therapy session
• Medication management (that belongs in the E/M component)
• Time when only a family member is receiving a separate family-therapy service

Practices migrating from E/M billing often make the mistake of applying the broad same-day-time methodology to psychotherapy. That methodology belongs to 99213/99214 — not to 90837, where only psychotherapy minutes count.

What documentation supports CPT 90837?

For 90837, the documentation burden is fundamentally different from E/M codes. Auditors are not testing MDM elements — they are testing whether real psychotherapy of sufficient duration actually occurred.

The note should include

• Clinician identity and signature
• Psychiatric/behavioral diagnosis
• Connection to the treatment plan
• Target symptoms or problems addressed
• Patient response and progress toward treatment goals
• Medical necessity for continued psychotherapy at 90837 frequency/duration
• Therapeutic interventions performed — name the modality & specific techniques
• Actual psychotherapy duration (start/stop times or total minutes — either method is acceptable under CMS psychotherapy rules)

A note reading “Psychotherapy provided for depression. Patient stable.” is significantly weaker than one identifying the target symptom, intervention used, patient response, and progress toward a specific treatment goal. 

OIG’s audit of On-Site Psychological Services found that inadequate treatment plans and missing therapeutic-intervention documentation were the primary reasons 111 of 120 claims failed.

For telehealth encounters, additionally document the modality (video vs. audio-only) and patient location. OIG’s 2025 telehealth settlement specifically targeted psychotherapy claims where the billed telecommunications modality was not actually used.

How much does CPT 90837 reimburse?

Payment depends heavily on provider credential — more so than most CPT codes. Medicare applies different payment percentages by practitioner type.

Provider type	2026 non-facility	2026 facility
Physician / Clinical psychologist	~$167.00	~$135.27
NP / PA / CNS (85%)	~$141.95	~$114.98
CSW / MFT / MHC (75%)	~$125.25	~$101.45
Commercial payers (median)	~$171.77	Varies
Medicaid	Varies by state	Varies

Medicare rates from CMS 2026 PFS national baselines. CSW/MFT/MHC rate reflects 75% of clinical psychologist amount. Commercial median from Transparency-in-Coverage data (Reddenda, 2026).

The $167 rate represents a meaningful 2026 increase — approximately 8.2% over the prior year — driven by CMS’s ongoing four-year behavioral-health RVU transition. The work RVU rose from 3.63 in 2025 to 3.78 in 2026.

MFTs and mental health counselors became Medicare-billable practitioners beginning January 1, 2024 — a major expansion of who can submit 90837 claims. 

However, their 75% payment rate means a ~$42 per-session gap compared to physicians and psychologists billing the same code.

Which modifiers apply to CPT 90837?

90837 is not an E/M code, so its modifier landscape differs from 99213/99214.

Modifier	When it applies
95	Synchronous audio-video telehealth
93	Audio-only telehealth (Medicare behavioral health has permanent audio-only eligibility)
90785 (add-on)	Interactive complexity — report with 90837 when maladaptive communication, caregiver involvement, or communication complications materially increase session complexity

Modifier 25 does not apply to 90837. Modifier 25 is an E/M modifier. 

If a psychiatrist performs medication management plus psychotherapy, the correct structure is the appropriate E/M code + 90838 (the 53+-minute psychotherapy add-on for use with E/M) — not 99214 + standalone 90837.

For Medicare telehealth, pair modifier 95 (audio-video) or 93 (audio-only) with POS 10 (patient home, ~$167 non-facility rate) or POS 02 (other location, ~$135 facility rate). 

Behavioral/mental-health telehealth has broader audio-only coverage than other service categories — Medicare permanently allows audio-only behavioral health under applicable conditions, and the in-person visit requirement remains waived through December 31, 2027.

CPT 90837 vs. 90834 — which one fits?

The 90834/90837 distinction is one of the cleanest boundaries in psychotherapy coding. Both represent individual psychotherapy without E/M — the only difference is session duration.

Feature	CPT 90837	CPT 90834
Service	Individual psychotherapy	Individual psychotherapy
Patient type	N/A	N/A
MDM	None	None
Time	53+ minutes	38-52 minutes
Descriptor	“60 minutes”	“45 minutes”
Medicare rate (2026)	~$167.00	~$113.90
Work RVU	3.78	2.56

Choose 90837 when actual psychotherapy reaches 53 minutes or more — documented with start/stop times or total minutes.

Choose 90834 when psychotherapy lasts 38-52 minutes. A 52-minute session is 90834, period. Do not round up.

The $53 payment difference creates a financial incentive to select 90837, which is precisely why payers audit it more aggressively than 90834. 

Practices that bill 90837 for 80%+ of sessions without clinical justification for consistently long treatment attract scrutiny. The documentation should explain why extended psychotherapy is medically necessary — not just that the session happened to run long.

What billing errors should you avoid with CPT 90837?

Seven mistakes drive the majority of 90837 denials and audit exposure.

1. Billing 90837 for 52 minutes or less 

The 53-minute threshold is absolute. A 52-minute session is 90834 regardless of what the schedule said or how the appointment was booked. Overstating duration is upcoding.

2. Adding charting and admin time to the psychotherapy clock 

90837 counts only qualifying psychotherapy interaction. Pre-session chart review, post-session documentation, scheduling, and care coordination do not count. Practices accustomed to E/M same-day-time rules often make this mistake.

3. Notes that do not identify actual psychotherapy 

“Provided psychotherapy for depression” tells an auditor nothing. 

Document the target symptom, therapeutic modality, specific interventions used, patient response, and progress toward treatment goals. 

OIG found 111 of 120 audited psychotherapy claims noncompliant — primarily due to missing therapeutic-intervention documentation and inadequate treatment plans.

4. Billing standalone 90837 with same-practitioner E/M 

When a psychiatrist or NP performs medication management plus psychotherapy, the structure is E/M + 90838 (the 53+-minute add-on). Standalone 90837 paired with 99214 by the same practitioner on the same date is the wrong combination.

5. Billing individual psychotherapy when group therapy occurred 

OIG has specifically pursued cases where 90837 was billed for sessions that were actually group psychotherapy. If multiple patients receive therapy together, use 90853.

6. Repeated long sessions without medical-necessity documentation 

Practices billing 90837 for the majority of sessions attract frequency audits. The treatment plan should explain why extended psychotherapy is clinically required — complex trauma processing, EMDR protocols, severe symptom acuity — rather than defaulting to hour-long sessions for every patient.

7. Incorrect telehealth modifier or modality documentation 

OIG’s 2025 settlement targeted telehealth claims where the billed modality was not actually used. Document video vs. audio-only, patient location, and the correct modifier (95 for video, 93 for audio-only). Do not submit modifier 95 for phone-only sessions.

Frequently asked questions about CPT 90837

Here are some commonly asked questions about CPT 90837: