Annual chart review guidelines for psychiatric providers

Updated

Psychiatric provider initial assessment: clinical documentation requirements

Applies to psychiatric provider intake notes

Note: This resource covers documentation requirements for Initial Assessments. Progress Notes 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, insightThis establishes the client's current condition, and the full set of elements gives a complete picture
HistoryPast behavioral health historyPrior treatment history present or absent. Type of treatment, if present. Who diagnosed / setting of any prior diagnosis. Psychiatric medications: current or not, plus prescribing provider. If none: document assessed and deniedEstablishes baseline and continuity of care, and identifies other prescribers whose regimens could interact with yours. 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, methamphetamineSubstance use changes diagnosis, risk, and prescribing decisions directly — several psychotropics are contraindicated or dose-limited with active use. An explicit denial or refusal is the record that screening occurred.
 Medical historyMedical conditions. Current medications — psychiatric and non-psychiatric, including supplements and OTC remedies. AllergiesPrescribing safety depends on the full medication list, not just psychotropics — interactions, contraindications, and hepatic/renal dosing all turn on it. Allergies are a documented safety check before any new prescription.
 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 deniedDocuments the psychosocial context 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 deniedTrauma history affects differential diagnosis (notably PTSD vs. adjustment vs. mood or psychotic disorders) and treatment selection.
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/dateRisk 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 daysAlso document: plan (presence/absence), intent (presence/absence), identified victim (if applicable), method including access to means (presence/absence), timeframe, protective factors, and overall risk levelThese are the elements that support a defensible risk-level determination and the clinical decisions that follow from it — including whether a prescribed medication is safe to dispense in quantity.
 

Safety planning


 

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

Abuse or neglect


 

If abuse or neglect involving a current minor, elder, or at-risk adult is disclosed, document either your mandated-report response or the rationale for why a report was not requiredMandated 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.
MedicationsRegimen detailFor every medication prescribed or managed: full medication name, dose, and frequencyThis information is vital for patient safety and must be documented consistently
 Clinical rationaleEvidence base and clinical rationale supporting each medication's use. If used off-label, explicitly document the clinical rationaleOff-label prescribing is lawful but requires a documented rationale to support medical necessity on review and to establish the reasoning if the choice is later questioned.
 Informed consentObtain and document for all medications. Document the risk/benefit discussion. The risk and side effect discussion must be specific to that medication, documented explicitly — not generic. Examples: lamotrigine — risk of serious skin conditions including Stevens-Johnson Syndrome and Toxic Epidermal Necrolysis; multiple CNS depressants — risk of sedation and overdose; bupropion — risk of seizures in clients at higher seizure riskInformed consent is a legal and ethical prerequisite to prescribing. A generic "risks and benefits discussed" does not evidence that the specific, material risks of that drug were conveyed.
Diagnostic justification A clear diagnosis supported by symptoms that align with DSM-5-TR criteria, including the onset or duration of symptoms when required to support the diagnosisInsurers check that each diagnosis is consistently and accurately documented

 

Psychiatric provider progress notes: billing & coding documentation requirements

Applies to Evaluation & Management progress notes — 99202–99205 and 99212–99215 — including the add-on psychotherapy codes 90833, 90836, 90838 and the interactive complexity add-on 90785. Initial evaluations (90792) have their own requirements.*

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
CPT code matches the claimThe code isn't required to appear in your documentation, but if you include it, it must match Headway exactly. Check every place it appears — header, body, any billing summaryIn audits, insurers look for any inconsistency between billed and documented coding
Date of service matches; note covers one sessionDOS in the note = DOS on Headway, and the note reflects a single date. Label historical dates or prior-session references as "historical background" or "prior history." Every billed session needs a standalone, unique note. Avoid a running list of updates with multiple dates and identical textClaims are tied to specific dates. Insurers deny "diary style" notes because they don't clearly support a single billable encounter
Place of service matchesPOS in the note = POS selected on HeadwayCoverage is regional; we need to know where the patient was to get the claim approved
Telehealth modality matchesTelehealth format in session details = format in the note: audio-visual vs. audio-onlySome plans restrict coverage for audio-only sessions
Patient identifiers match the claimName and DOB in the note = patient's Headway details. Check the profile for nickname or date discrepanciesInsurers need exact name and DOB matches to confirm you're billing for the right person
Rendering provider matches the claimBill under the provider who directly delivered the careThis is "incident-to" billing, which some states and payers allow. Headway does not support it today
Service is supported at HeadwayIf a service isn't supported on Headway, bill it outside of HeadwayHeadway's payer agreements cover a large range of CPT codes, but not every possible code
Patient name and DOB on every pageFull legal name and DOB on every page. A preferred name can be included, but the legal name still has to appearImproves accuracy and historical record keeping
Place of service is allowedOutpatient codes (11, 02, 10) can't be billed while a patient is receiving inpatient or residential care — the facility bills thoseCoverage is regional; we need to know where the patient was to get the claim approved

Clinical content

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

RequirementWhat to documentWhy it's required
The note justifies the E/M level billedSelect an E/M code appropriate for the time and/or complexity, and show that reasoning. With a psychotherapy add-on, level the E/M using medical decision-making, not time. Justify the level of MDM you selected. The elements you relied on should be visible in the note, not impliedInsurers want to know the time spent and level of care were justified by the patient's needs and current condition
Interactive complexity (90785) is supportedDocument both the communication barrier and its impact: barriers include maladaptive communication, caregiver behavior, or severe emotional dysregulation; what you did to address it; the circumstances it created — disrupted treatment, redirection, additional time90785 pays additional money, so insurers want to ensure the code is warranted
Person-centered detailSpecific detail about the patient from this particular session. Consider direct quotes; avoid generic notes — "Patient is doing well" could apply to anyoneShows care is tailored to this patient and that the note documents a particular session
Diagnosis matchesDiagnosis entered on Headway = your note, consistent throughoutInsurers check that each diagnosis is consistently and accurately documented
Mental status examAt least 7 core elements: orientation, appearance, speech, mood, thought process, thought content, judgmentEstablishes the patient's current condition; the full set gives a complete picture
Course of treatment and progress toward goalsA recommended course of treatment, plan, or goal, plus a statement on how the patient is progressing. If they aren't progressing, say soDemonstrates you're actively evaluating whether care is working, and adjusting it
Medications with name, dosage, and frequencyList the medications you're managing with names, dosages, and frequencies, plus any changes made at this encounterVital for patient safety and must be documented consistently

Psychotherapy section

When you bill add-on psychotherapy, this content lives in its own section, separate from medication management.

RequirementWhat to documentWhy it's required
All psychotherapy content sits in a distinct sectionA dedicated psychotherapy section, clearly separate from medication management, with all therapy content inside it. An auditor should be able to draw one line where E/M ends and psychotherapy begins — no E/M content below that line. Include issues addressed, interventions used, the therapy plan or goal, and progress toward itWhen you bill a separate therapy service, the psychotherapy content should be visually and structurally separate from the E/M (SOAP) note
Psychotherapy time supports the add-on code

Exact time spent on psychotherapy, matching the add-on code selected. E/M and therapy time cannot overlap. Include the length of both the medication management portion and the therapy portion. Avoid ranges — "16–37 mins" or ">16 mins" will not support the code. Document exact minutes.

Example: Total session time: 10:00 AM – 11:00 AM · Psychotherapy time: 10:20 AM – 11:00 AM

If the note shows a single block of time, or therapy time isn't exact, auditors can't verify how much of the appointment was therapy only, and the claim will be denied
Psychotherapy time stated separately from total timePsychotherapy duration, or its start and stop times, documented separately from total appointment time. Include both portions of the encounter — one combined block does not support the add-onInsurers view these as two distinct services and review each separately. Billing a blend without clear timing distinctions can lead to denials
Symptoms and concerns addressed with therapy

The symptoms or concerns you addressed with therapy, restated inside the psychotherapy section even if they overlap with medication management.

Example: Symptoms/concerns addressed in psychotherapy: anxiety with rumination, irritability, sleep disruption, and difficulty managing stressors.

Reviewers look for clear evidence that psychotherapy was performed in addition to medication management. If therapy content isn't restated in the therapy section, the add-on can be missed
Therapy interventions used

Name the interventions (CBT, DBT) and what you addressed with them. Pair alternative practices with an evidence-based practice.

Example: Used cognitive-behavioral therapy techniques to address social anxiety.

Insurers need to verify which clinical methods you're using in order to approve claims
Therapy goals and progress toward them

The patient's therapy goals and their progress, inside the psychotherapy section. Capture a lack of progress too.

Example: Tom made progress toward his treatment plan goal of managing social anxiety, as evidenced by two successful public outings where he practiced mindfulness and breathing techniques.

Shows you're actively evaluating whether care is working and adjusting it

Signature

How you close and date the note.

RequirementWhat to documentWhy it's required
Complete provider signatureFirst and last name, credentials, and the date signed. An electronic signature also needs a statement such as "signed by" or "electronically signed by"Confirms you are the person who provided the care
Signed within 7 daysWithin 7 days of the date of service. For Medicare and Medicaid, within 48 hoursInsurers require this timeline so session details are still fresh
Licensure credentialsLicense type clearly present in the note — for example LCSW, MD, or NPInsurers check license type to confirm care was provided by an appropriate professional

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 rendersRemove any password protection and upload a readable version. Common causes of failure: password-protected PDFs, corrupted files, unsupported formats. Exporting straight from your EHR as a standard PDF avoids most of themInsurers have to be able to open and read your documentation to verify care was provided
Note is legibleUpload a typed, text-based version. Screenshots of an EMR and handwritten notes cannot be reviewed. Download from your EHR as a PDF rather than taking a screenshot. If handwritten, type and re-sign before uploadingInsurers have to be able to read every part of the documentation
Completed progress noteUpload a finalized, signed note — if submitted in draft, sign it and re-upload. A complete note includes a full signature: name, credentials, and date. Watch for treatment plans or intake forms uploaded in place of a progress noteInsurers require a completed, signed progress note for each session to verify care was rendered
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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