Guide

90791 vs 90792: the intake codes and who may bill each

Summary

90791 is the psychiatric diagnostic evaluation without medical services; 90792 is the same evaluation with medical services — medication review, physical-health assessment tied to the diagnosis, and a medical treatment plan — included. The choice turns on scope of practice and what actually happened in the visit, not on session length or complexity: psychologists, social workers, counselors, and marriage and family therapists bill 90791, while psychiatrists, psychiatric nurse practitioners, and physician assistants performing genuine medical evaluation bill 90792.

By Gale Editorial · Updated 2026-07-26. Every figure cited to a dated source. How we write.

When do you bill 90791 versus 90792?

90791 is the psychiatric diagnostic evaluation without medical services; 90792 is the same evaluation with medical services included. The choice between them turns on scope of practice and what the evaluation actually included, not on how long the session ran or how complex the case was 1. A non-prescribing clinician — a psychologist, licensed clinical social worker, licensed professional counselor, or marriage and family therapist — bills 90791; a psychiatrist, psychiatric nurse practitioner, or physician assistant who incorporates a medical evaluation into the same visit bills 90792 instead.

The distinction isn't a matter of choosing the code that pays more or better matches a preferred billing pattern — it tracks what actually happened in the room and who was clinically and legally positioned to do it. How often either evaluation code can be repeated for a returning client is a separate question from which one applies at the outset — re-billing 90791 turns on payer frequency policy, not on scope of practice.

What "medical services" actually means in this distinction

90792 adds a medical component to the standard diagnostic evaluation: elements tied to prescribing and medical management, such as reviewing a client's medication history, assessing physical health factors relevant to a psychiatric diagnosis, and forming a medical treatment plan alongside the psychiatric one. 90791 covers the same core evaluation — history, mental status, risk assessment, and a treatment plan — without that medical layer 1.

That's why the two codes aren't interchangeable options for the same visit: a clinician whose scope of practice doesn't include prescribing or ordering medical treatment isn't performing the medical-services component 90792 is built around, regardless of how thorough the rest of the evaluation is.

Who can bill each code

90791 is the code most solo behavioral-health clinicians use for an initial evaluation: psychologists, licensed clinical social workers, licensed professional counselors, and marriage and family therapists all bill it, and Medicare's 2024 expansion to cover licensed marriage and family therapists and licensed mental health counselors as billing providers didn't change which evaluation code they use — they bill 90791, not 90792, since the medical-services component sits outside their scope of practice 2.

90792 belongs to clinicians whose license and training include the medical elements the code describes — psychiatrists, psychiatric mental health nurse practitioners, and physician assistants practicing in a psychiatric role. A prescriber conducting an intake that genuinely includes medical evaluation and management bills 90792; a prescriber who runs a purely psychiatric interview without the medical component would still document what was actually done before defaulting to the code with medical services attached.

What both codes share

Both codes describe a one-time diagnostic evaluation rather than an ongoing treatment code, and both belong to intake day — the start of an episode of care — not to the codes that follow it. Neither carries a CPT-published time cap the way the timed psychotherapy codes do; the long intake can run as long as the clinical picture requires, whether it's billed as 90791 or 90792. Both are governed by the same CPT code set the AMA's Editorial Panel maintains and updates annually 3.

Neither code is billed alongside the other for the same visit — a single evaluation is either 90791 or 90792, never both, because they describe the same underlying service at two different scopes rather than two separate, stackable services. Once the evaluation is billed, ongoing individual care shifts to the 90832, 90834, 90837 time bands, a same-day crisis presentation would instead fall under 90839 and 90840, and ongoing family work belongs to 90847: family sessions, one identified patient — none of which the initial evaluation code has any bearing on.

Telehealth and the evaluation codes

Both 90791 and 90792 can be delivered by telehealth, and CMS publishes the definitive list of which codes are payable as Medicare telehealth services each year, including which are permanent additions versus temporary and which are eligible for audio-only delivery 4. Confirming a code's current telehealth status against that published list before billing a remote evaluation is worth doing every year, since the list changes and a code's telehealth eligibility isn't fixed permanently by its CPT definition.

The code choice itself — 90791 versus 90792 — doesn't change based on delivery method; a prescriber conducting a genuinely medical evaluation by video still bills 90792, and a non-prescribing clinician still bills 90791, regardless of whether the visit happened in person or on a screen.

Family involvement changes the confidentiality math, not the code

An evaluation that includes conversation with a parent, spouse, or other family member to gather history doesn't change whether the visit is billed as 90791 or 90792 — that choice still turns on scope of practice and the medical-services question, not on who else was in the room. What does change is confidentiality: HIPAA's mental-health-specific guidance on when a provider may talk with family members governs what can be disclosed during that conversation, independent of which evaluation code the visit is billed under 5.

Documenting the informed consent for that family conversation — what the client agreed to have discussed, and with whom — belongs in the note regardless of which code applies, since the confidentiality question and the coding question are decided by two different sets of rules that happen to intersect in the same visit.

Common billing mistakes with these two codes

The most common error is a non-prescribing clinician billing 90792 because it's the code they've seen a psychiatrist colleague use, without actually performing or being licensed to perform the medical-services component the code requires — that mismatch between what was documented and what the code claims is exactly what a payer audit catches.

The reverse mistake also happens: a prescriber who did incorporate genuine medical evaluation and management into the intake under-bills with 90791 instead, leaving legitimate reimbursement for the medical component on the table. The fix for both is the same — document what was actually done during the evaluation, then match the code to that documentation rather than to habit or to what a colleague bills.

Common questions

Not for a typical evaluation. 90792 requires the medical-services component the code is built around, which sits outside the scope of practice for psychologists, licensed clinical social workers, professional counselors, and marriage and family therapists. Those clinicians bill 90791 for an initial diagnostic evaluation.

The presence of a genuine medical-services component — reviewing medication history, assessing physical health factors relevant to the psychiatric diagnosis, and forming a medical treatment plan alongside the psychiatric one. Without that medical layer, the same evaluation is billed as 90791 regardless of who performs it.

No. Medicare's 2024 expansion added those provider types as eligible billers, but it didn't change what each code requires. They bill 90791, the evaluation without medical services, because the medical-services component of 90792 still sits outside their scope of practice.

No. They describe the same underlying diagnostic evaluation at two different scopes, not two separate services. A single evaluation is billed as one or the other, never both, based on whether the medical-services component was genuinely part of that visit.

No. Whether a parent, spouse, or other family member participates doesn't affect the 90791-versus-90792 decision, which turns on scope of practice and the medical-services question. It does raise a separate confidentiality question about what can be disclosed during that conversation.

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References

  1. 1.APA Services, Inc. (2025). Psychotherapy Codes for Psychologists. APA Services, Inc.. link ✓Supports the 90791/90792 distinction — evaluation without versus with medical services — and that the choice tracks scope of practice, not session complexity.
  2. 2.Centers for Medicare & Medicaid Services (2025). Medicare and Mental Health Coverage. CMS Medicare Learning Network (MLN1986542). link ✓Supports that Medicare's 2024 coverage expansion to MFTs and mental health counselors made them eligible billing providers without changing which evaluation code applies to their scope of practice.
  3. 3.American Medical Association (2026). CPT® (Current Procedural Terminology). American Medical Association (AMA). link ✓Supports that both 90791 and 90792 are governed by the same CPT code set maintained and updated annually by the AMA's CPT Editorial Panel.
  4. 4.Centers for Medicare & Medicaid Services (2026). List of Telehealth Services. Centers for Medicare & Medicaid Services (CMS). link ✓Supports that CMS publishes an annually updated list of which codes, including the evaluation codes, are payable as Medicare telehealth services and under what conditions.
  5. 5.HHS Office for Civil Rights (2026). HIPAA Privacy Rule and Sharing Information Related to Mental Health. U.S. Department of Health and Human Services. linkSupports that talking with a family member during an evaluation is governed by HIPAA's mental-health-specific disclosure guidance, independent of which evaluation code applies.

https://www.gale.care/for-providers/bhc-90791-vs-90792 · 5 sources. Competitor details are cited to dated public sources and maintained as they change; figures are estimates, not commitments. Synthetic demonstration.

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