Annual chart review guidelines for talk therapists

Updated

Initial assessment: clinical documentation requirements

Applies to talk therapy intake notes

Note: This resource covers documentation requirements for Initial Assessments. Progress notes (see below) differ in some areas, but the clinical guidance here applies wherever the two overlap.

SectionSubsectionWhat to documentWhy it's required
Assessment — Mental Status Exam (MSE) Comprehensively assess and document in a clearly grouped section: attention, orientation, appearance, behavior, speech, mood, affect, thought process, thought content, memory, judgment, insight.The MSE provides insight into  the client's current condition, and the full set of elements gives a complete picture
HistoryPast behavioral health historyDocument any past history of behavioral health treatment and diagnoses. Who diagnosed / setting of any prior diagnosis. Psychiatric medications: current or not, plus prescribing provider. If none: document assessed and denied.Establishes baseline and continuity of care, and shows the current diagnosis was formed with knowledge of prior treatment. If there is no history, documenting "assessed and denied" proves the area was addressed rather than skipped. 
 

Alcohol and substance use (client 12+)


 

Current use: yes/no. If endorsed: substance(s), amount, and frequency. If denied or declined: document the client's response. Substances to assess: tobacco/nicotine, alcohol, cannabis, cocaine, hallucinogens, opioids, methamphetamine.Substance use can impact a client’s diagnosis, risk, and treatment planning, and screening is an expected component of a comprehensive assessment. If applicable, documenting a client’s denial or refusal is the record that screening occurred. 
 Family, occupational, and social historyRelevant background on family relationships, living situation, employment or school status, and social supports. Any factors impacting functioning or symptoms. If none reported: document assessed and denied.Gives context into psychosocial elements and functional impairment that support medical necessity for the diagnosis. 
 Trauma historyPast trauma: yes/no. If yes: type, approximate timing or life period, and current impact on functioning or symptoms. If no: clearly document that it was assessed and denied.Trauma history can affect differential diagnosis (notably PTSD vs. adjustment vs. mood disorders) and treatment approach. 
Risk & Safety  

Four risk domains


 

For each of suicidal ideation, homicidal ideation, self-harm/NSSI, and harm to others: current presence or absence, plus any history. If any behavior is reported, document the method and approximate timeframe/date.Risk assessment is a core standard of care in an initial evaluation, and explicit presence-or-absence documentation is what demonstrates it was performed. 
 If risk is present currently or within past 30 daysDocument: plan (presence/absence), intent (presence/absence), identified victim (if applicable), method - including access to means (presence/absence), timeframe, protective factors, and overall risk level.These elements support a defensible risk-level determination and the clinical decisions that follow from it. 
 

Safety planning


 

Required if the client has active SI/HI with a plan, or active ideation or a suicide attempt within the past 30 days. Develop the Safety Plan collaboratively and document the review. Include key elements: coping strategies, supportive contacts, crisis resources, means restriction. Include referrals or higher level of care, if applicable.Document that an identified risk was actively managed, not just recorded. This is a clinical and liability standard, and a best practice for client care. 
 

Abuse or neglect


 

If abuse or neglect involving a current minor, elder, or at-risk adult is disclosed, document either your mandated reporter response or the rationale for why a report was not required.Mandated reporting obligations are set by state law and vary; the note is the record of how the obligation was discharged or why it did not apply. 
Golden Thread Chief complaintThe client's reason for seeking treatment: 1–2 sentences in the client's own words, and/or a brief description of current concerns or symptomsAnchors the note to this client and this session encounter, and is the starting point the diagnosis and plan have to trace back to. 
 DiagnosisA clear diagnosis supported by symptoms that align with DSM-5-TR criteria, including onset or duration of symptoms where required to support the diagnosisInsurers check that each diagnosis is consistently and accurately documented, and a clinically appropriate diagnosis is a part of ethical client care.
 Connection to presenting problemThe primary diagnosis should connect to the presenting problem or other documented symptoms, concerns, and/or functional impairments described in the note.This linkage is what establishes medical necessity — a diagnosis with no documented connection to presenting symptoms won't support the claim. 
 Evidence-based treatment (EBT)Name the EBT or therapeutic approach used (e.g., CBT, DBT, ACT, EMDR, exposure therapy) in session. Name a specific intervention or technique delivered this session. State the link between the intervention and the diagnosis, presenting problem, documented symptoms, and/or treatment goals.Insurers need to verify which evidence-based methods were used to confirm the services provided match the CPT code billed.
 PlanExpected appointment follow-up interval (when the client will be seen next) and the primary focus of the next session or ongoing treatment.This demonstrates you are actively evaluating whether care is working, and adjusting it when clinically indicated.

 

Progress notes: billing & coding documentation requirements

Applies to talk therapy and psychotherapy progress notes — 90832, 90834, 90837 — and the interactive complexity add-on 90785.

Header and session details

The details at the top of the note, and everything that has to agree with your session confirmation.

RequirementWhat to documentWhy it's required
Start/stop times support the codeExact start and stop times (not just duration). Face-to-face time only — no chart review or note writing. 90832 = 16–37 min · 90834 = 38–52 min · 90837 = 53+ minPsychotherapy codes are time-based; insurers verify length matches the code
CPT code matches the claimIf you include the code anywhere — header, body, billing summary — it must match Headway exactly. Not required to appear at allAudits flag any billed-vs-documented coding inconsistency
Date of service matches; one session per noteOne standalone, unique note per billed session. Label prior-session content "historical background" or "prior history." No running multi-date lists with identical textClaims tie to specific dates; "diary style" notes get denied
Place of service matchesPOS in the note = POS selected on HeadwayCoverage is regional; payers need the client's location
Telehealth modality matchesAudio-visual vs. audio-only must match session detailsSome plans restrict audio-only coverage
Client identifiers matchName and DOB in note = client's Headway profile. Watch nicknames and date discrepanciesExact match confirms you're billing for the right person
Rendering provider matchesBill under the provider who directly delivered the careHeadway does not support "incident-to" billing
Service is supported at HeadwayIf the code isn't supported, bill outside HeadwayHeadway's payer agreements cover many but not all CPT codes
Name + DOB on every pageFull legal name and DOB on each page; preferred name optional but legal name requiredAccuracy and historical record keeping
Place of service is allowedOutpatient codes (11, 02, 10) can't be billed during inpatient or residential care — the facility bills thoseCoverage is regional; payers need the client's location

Clinical content

The body of the note: what you observed, what you assessed, and what you did.

RequirementWhat to documentWhy it's required
Documentation supports the CPT codeType, format, and duration must align. 90832/90834/90837 need documented psychotherapy — not care coordination, case management, or phone check-ins. If format changed mid-session (partner/parent joined), document it and bill the matching codePayers confirm services rendered match the code's type and level of care
Interactive complexity (90785)The communication barrier (maladaptive communication, caregiver behavior, severe emotional dysregulation), what you did about it, and the circumstances it created (disrupted treatment, redirection, added time)90785 pays extra, so payers verify it's warranted
Person-centered detailSpecifics from this session; consider direct quotes. Client is doing well could apply to anyoneShows care is tailored to this client and this session
Interventions usedName the specific intervention (CBT, DBT, MI) and what it addressed. "Provided supportive therapy" is too vaguePayers verify the evidence-based methods match the code billed
Course of treatment + progressRecommended course/plan/goal plus a statement on progress. If the client isn't progressing, say soShows you're actively evaluating and adjusting care
Diagnosis matchesDiagnosis entered on Headway = note, consistent throughoutPayers check each diagnosis is consistently documented
Mental status examAt least 7 core elements: orientation, appearance, speech, mood, thought process, thought content, judgmentEstablishes current condition; full set gives a complete picture

Signature

How you close and date the note.

RequirementWhat to documentWhy it's required
Complete provider signatureFirst and last name, credentials, date signed. E-signatures need "signed by" or "electronically signed by"Confirms you provided the care
Signed within 7 days7 days of DOS; 48 hours for Medicare and MedicaidDetails stay fresh
Licensure credentialsLicense type clearly present (LCSW, MD, NP)Confirms an appropriate professional delivered care

File and format

The file itself has to be readable and complete before it can be reviewed.

RequirementWhat to documentWhy it's required
Note opens and rendersNo password protection. Export straight from your EHR as a standard PDF; watch for corrupted or unsupported formatsPayers must be able to open the file
Note is legibleTyped, text-based. No EMR screenshots, no handwritten notes — type and re-sign handwritten ones firstPayers must be able to read every part
Completed progress noteFinalized and signed with name, credentials, and date. Not a draft, treatment plan, or intake formPayers require a completed signed note per session
Disclaimer: This document is for educational purposes only and is not intended as professional or legal advice. It may contain errors or missing information, and recent changes in policies, regulations, or payer requirements may not be reflected. Because requirements vary by organization and jurisdiction, please consult legal counsel, the appropriate regulatory or licensing authority or your designated Headway contact for guidance specific to your situation.

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