Chart reviews and audits on Headway


We know the thought of an insurer review can be stressful. Headway is here to help: in the event of a review, we’ll let you know exactly what you need to submit, by what deadline, and where you may need to add addenda to your documentation.


Reviews from Headway and insurers

A dedicated, specialized team at Headway reviews documentation periodically to help support providers. Internal reviews are driven by insurer and regulatory standards as part of healthcare operations. Through these reviews, we can help improve documentation practices and better prepare for potential insurer reviews.


During the review

When your documentation is needed for a review, we’ll let you know right away. We’ll highlight relevant sessions in Sigmund, and—if applicable—highlight the items that likely need to be updated before submission. 

This might mean we request that you upload an existing treatment plan or progress note on Headway. If your notes are already stored on Headway, we’ll flag any potential issues—such as a session length not properly matching the CPT code.

You’ll have a chance to review these queries, include any addenda as necessary, then submit your documentation. Check out this resource to see 10 of the items most commonly missing from chart documentation. 


Who sees your clients’ charts (progress notes, treatment plans, etc.)

Headway limits requests, use, and disclosure of protected health information to what is minimally necessary to accomplish the intended purpose of the appropriate request, use or disclosure. An example of this is if a chart review is required for the purposes of processing insurance or ensuring compliance. 

A dedicated, specialized team at Headway may review your charts, but only for the purposes of processing insurance, ensuring compliance and performing other payment and healthcare operations functions. In addition, Headway team members receive specialized training on HIPAA, the importance of PHI safety, and the “minimum necessary” rule. Headway also proactively maintains an audit log of all access to patient records. 

If you have further questions or suspect any misuse, please contact us.


How Headway keeps your documentation and data secure

Headway will only share PHI (personal health information) for reasons allowed or required by HIPAA, such as for treatment, payment, or healthcare operations. Headway will not share, sell or otherwise distribute the documentation to anyone else. As part of Headway’s mission to create a mental healthcare system everyone can access, we are trusted with individuals’ most sensitive information. We take this very seriously.

We’re trusted with individuals’ most sensitive information, and take protection very seriously. We’ve built a secure infrastructure and platform, maintain SOC 2* and HIPAA compliance, and follow industry best practices regarding cloud infrastructure and encryption. 

*SOC 2 stands for Service Organization Control 2 and is a security framework that defines how companies should manage, process, and store customer data.


Keeping documentation on Headway

Complete clinical documentation is both required by mental health licensing laws and by insurance to pay for covered services. Currently, we do not require all providers to keep documentation on Headway.  In the event of a review or audit, you will be required to share your documentation—such as specific treatment plans and progress notes—with us. However, you are usually given the option to note that your documents are "saved elsewhere." (Note that we will not require therapists to share private, psychotherapy notes, which most providers use purely for their own use.)

We are constantly evolving how we work with insurance to best support providers and patients. While right now it is usually optional to save your documentation on Headway, this may evolve over time given insurance requirements. We will continue to be transparent with you as expectations change.


Preparing for a documentation review

The best way to prepare for a review is to keep strong documentation and to follow Headway’s guidance on coding and documentation. If you use Headway documentation templates and keep your notes on Headway, we’ll often be able to address any insurer requests with no additional action from you. For more details on the requirements for strong documentation, see our Documentation Policy here.

If you choose to keep your documentation outside of Headway, you’ll simply need to provide that documentation in a timely manner if an insurer makes a request (typically within 3 days). The 3 day window allows us to review and prepare documentation for the insurer review while still meeting their timeline.


How Headway handles clawbacks

Headway views clawbacks as a last resort. As your practice partner, our goal is to work collaboratively to resolve any concerns that arise. We’ll reach out to providers if an insurer contacts us with a payment-related issue.

If a provider is unresponsive to our requests, it can be difficult for us to understand the services provided, and we may have to return the payment to the insurer or adjust the provider's payments to reflect this. In the rare event we have to adjust a provider's payment, we will communicate to the provider.  

Headway and our payer partners always expect that you’re using good faith judgment in choosing the right CPT and diagnosis codes for sessions, and that you are keeping notes (on Headway or elsewhere) that support this. We aim to always protect you from “clawbacks” (i.e., avoidance of recouping payments already made) on sessions you’ve submitted.


Preventing recoupment of payments

The great news is that these recoupment circumstances are avoidable. To ensure this, keep a few things in mind:

  • Always code accurately and compliantly. We offer some coding guidelines, but we encourage you to consult other resources of your choice as well.
  • Follow guidelines for progress notes
  • Consider “medical necessity” when coding—e.g., does the client have an applicable behavioral health diagnosis for this type of care?
  • Be responsive to clients or Headway team members when asked about session coding, documentation requests, cancellation fees or circumstances
  • Keep your notes on Headway or another HIPAA compliant platform, and be sure to supply them promptly if requested

In most cases, we will reach out to you directly if there’s a complication or question about the way something is submitted. We’ll do our best to avoid surprising you or editing your payments, and make an effort to work with you in advance if this comes up. You can review the provider guidelines anytime, and we’re here to help and give feedback!


Support Headway offers 

You’re not on your own. We are your practice partners and we are proud to provide a variety of supporting materials, templates, example documentation and other resources. See our compliance guide to get started.


Frequently asked questions

What if I make an error when confirming sessions? 

In the event of a provider error, Headway may reach out to discuss the situation and any implications to how the claim will be paid.

This could include:

  • Sessions coded in a way that does not align with CPT/ ICD-10 or payer guidelines
  • Instances where the CPT or diagnosis codes chosen don’t represent the services performed or session notes
Is payment guaranteed if there is a mistake on Headway’s end?

Headway makes sure you’re paid in the event that we’ve made a mistake or given a client inaccurate information regarding their coverage, even if there are complications with their claims.

This could include:

  • Instances where we incorrectly told a client you were in their network
  • If their benefits ended or changed without our system catching it
  • There was a qualification or authorization required on their plan that we didn’t know of when they booked

In any of these cases, we will ensure that you are paid your contracted rate for your time and services, whether your client was ultimately covered or not if the mistake is on Headway's end.

What if I don't pass a review?

Much of the time, failing to pass a review simply means there were additional details the insurer didn’t see in the documentation you submitted. In these cases, we’ll follow up with you to add these missing details.

In other cases, an insurer review may reveal a pattern of mistakes or behavior that will take more time to address. In these cases, we’ll work with you to understand and address the issues going forward. For more details on the steps we’ll take, see our Curative Action Policy.

How far back will insurers audit?

Headway’s medical record retention policy is 10 years; our expectation is that you can produce any records requested for that range. While that is the full range, we experience a high volume of insurer audits for dates of service up to 3 years in the past.



This document is intended for educational purposes only. It is designed to facilitate compliance with payer requirements and applicable law, but please note that the applicable laws and requirements vary from payer to payer and state to state. Please check with your legal counsel or state licensing board for specific requirements.

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