No, You Cannot Bill 90836 and 99215 Together
You cannot bill CPT codes 90836 and 99215 for the same patient on the same day, as this constitutes double billing for overlapping services. 1
Why This Is Considered Double Billing
CPT code 90836 is a combination code that already bundles psychotherapy with evaluation and management (E/M) services into a single billable unit. 1 When you bill 90836, you are already being reimbursed for both the psychotherapy component and the medical E/M work—adding 99215 would mean billing twice for the same work. 1
The American Academy of Child and Adolescent Psychiatry explicitly states that billing 90836 alongside any E/M code from the 99211-99215 series results in inappropriate double billing for overlapping services. 1
The Correct Billing Approach
Bill 90836 as your primary and only code when providing psychotherapy with medical E/M services during the same encounter. 1 This single code captures both components of your clinical work:
- The psychotherapy intervention
- The medical evaluation and management activities (medication review, treatment planning, medical decision-making)
Choose from the psychotherapy add-on codes (90833,90836, or 90838) based on the total time spent in psychotherapy, as these codes already include the E/M component. 1
Documentation Requirements
To properly support billing 90836, your documentation must include: 1
- Psychotherapy component: Specific therapeutic interventions, techniques used, patient response
- Medical E/M component: Medical decision-making, medication management, treatment plan modifications
- Total time spent: Document face-to-face time to justify the specific add-on code selected
- Medical necessity: Clear indication that both psychotherapy and medical management were clinically necessary during this encounter
Common Pitfall: Non-Physician Providers
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 These providers should use standalone psychotherapy codes (90832,90834,90837) instead.
Telemedicine Considerations
For telehealth services, the same bundling rules apply. 1 Both psychotherapy codes and E/M codes can be billed with modifier 95 for telemedicine, but 90836 already includes the E/M component, so adding 99215 remains inappropriate even when services are delivered via telehealth. 1 The American Academy of Child and Adolescent Psychiatry confirms that 90836 and other combination psychotherapy codes (90833,90838) are billable via telemedicine with the appropriate modifier. 2
Regulatory Context
The American Academy of Child and Adolescent Psychiatry lists both 90836 and 99215 as separately billable codes for telemedicine services, but this refers to their use in different clinical scenarios—not together on the same day for the same encounter. 2 When psychotherapy and E/M occur during the same visit, the combination code (90836) is the only appropriate billing option.