Billing 90836 and 99215 Together: Not Permitted on the Same Day
You cannot bill both CPT code 90836 (psychotherapy with E/M) and 99215 (office visit) for the same patient on the same day—this constitutes double billing for overlapping services. 1
Understanding the CPT Code Structure
What 90836 Actually Includes
- CPT 90836 is a "combination code" that already bundles psychotherapy (approximately 38-52 minutes) with evaluation and management services 1
- The code specifically exists to capture both the psychiatric/psychotherapy work AND the medical E/M component in a single billable service 1
- When you bill 90836, you are already being reimbursed for the E/M portion—adding 99215 would mean billing twice for the same work 1
The Correct Billing Approach
If providing psychotherapy with medical E/M services:
- Bill 90836 (or 90833/90838 depending on time spent) as your primary code 1
- This single code captures both components of your work
- Do not add any 99211-99215 codes 1
If providing E/M services without psychotherapy:
- Bill the appropriate office visit code (99211-99215) based on time or medical decision-making complexity 2, 3
- For 99215 specifically: requires either 40-54 minutes total time OR high complexity MDM 2, 3
If providing psychotherapy alone without medical E/M:
- Bill standalone psychotherapy codes: 90832 (16-37 minutes), 90834 (38-52 minutes), or 90837 (53+ minutes) 1
- These codes do NOT include E/M services 1
Common Pitfall: Clinical Psychologists and Clinical Social Workers
Important restriction: Clinical psychologists and clinical social workers cannot bill CPT codes 90833,90836, or 90838 under Medicare, as these practitioners are not permitted to bill for services that include medical evaluation and management 1
- Only physicians, physician assistants, nurse practitioners, clinical nurse specialists, and nurse-midwives can bill the combination psychotherapy codes (90833/90836/90838) 1
- CPs and CSWs must use standalone psychotherapy codes (90832,90834,90837) 1
Documentation Requirements
When billing 90836, your documentation must support:
- The psychotherapy component (content, techniques, therapeutic interventions) 1
- The medical E/M component (history, examination if performed, medical decision-making) 1
- Total time spent if using time-based billing 2, 3
- Clear indication that both psychotherapy AND medical management were medically necessary 1
Telemedicine Considerations
For telehealth services, both psychotherapy and E/M codes can be billed with modifier 95 (for interactive audio-video) 1
- The same bundling rules apply: 90836 already includes E/M, so adding 99215 remains inappropriate even via telemedicine 1