Billing the work between sessions: what 90887 and 90889 cover

Do 90887 and 90889 pay for between-session work?

Rarely, and one contractor says so in writing. Wisconsin Physicians Service, the Medicare Administrative Contractor whose billing article covers psychiatry and psychology services, states that CPT 90885, 90887 and 90889 are incidental services and are not separately payable 1Ref 1Wisconsin Physicians Service Insurance Corporation (Medicare Administrative Contractor), for the Centers for Medicare & Medicaid Services (2026).Billing and Coding: Psychiatry and Psychology Services (A57480).The statement that CPT 90885, 90887 and 90889 are incidental services and not separately payable, its status as one MAC's Medicare policy rather than a national rule, and the article's original and revised effective dates.. That article carries a revision effective January 1, 2026. It binds that contractor's jurisdictions and no others, and it says nothing about commercial payers.

90889 has not disappeared from Medicare, which is part of why the code confuses people. CMS's Medicare and Mental Health Coverage booklet, March 2026 edition, lists it in the table of commonly used mental health codes as preparation of report of patient's psychiatric status, history, treatment, or progress 2Ref 2Centers for Medicare & Medicaid Services, Medicare Learning Network (2026).Medicare & Mental Health Coverage.The listing of 90889 as report preparation in CMS's table of commonly used mental health codes, the asterisk and dagger marks and which codes they flag, the G0544 post-discharge follow-up contacts intervention and its consent and call limits, and Medicare coverage of family psychotherapy with or without the patient present.. A listing in that table says only that the code exists; it is not a payment decision.

Two marks in the same table are worth reading before anyone plans a month around 90889. An asterisk flags current telehealth codes, and a dagger flags the codes clinical psychologists, clinical social workers, marriage and family therapists and mental health counselors can bill 2Ref 2Centers for Medicare & Medicaid Services, Medicare Learning Network (2026).Medicare & Mental Health Coverage.The listing of 90889 as report preparation in CMS's table of commonly used mental health codes, the asterisk and dagger marks and which codes they flag, the G0544 post-discharge follow-up contacts intervention and its consent and call limits, and Medicare coverage of family psychotherapy with or without the patient present.. In the March 2026 edition, 90889 carries neither mark, which tells a non-prescribing clinician most of what she needs to know before building a workflow on it.

Ask instead which code pays for the work you did between the sessions.

The Medicare codes that pay for time outside the room

Three families, all monthly, all built on non-face-to-face minutes that accumulate across a calendar month. Care management for behavioral health conditions under HCPCS G0323 covers at least 20 minutes of clinical psychologist or clinical social worker time per calendar month, including facilitating and coordinating treatment and coordinating with prescribers, and CPT 90791 serves as its initiating visit 3Ref 3Centers for Medicare & Medicaid Services (2024).Behavioral Health Integration Services.The Medicare routes that pay for non-face-to-face behavioral health work: G0323 care management and its 90791 initiating visit, 99484 general behavioral health integration, collaborative care management under 99492-99494 and G2214, the G0546-G0551 interprofessional consultation tiers and who may bill them, and the cost-sharing notice and documented verbal consent required before services begin..

General behavioral health integration is the next step out. CPT 99484 involves at least 20 minutes of clinical staff time per calendar month under a physician or other qualified health care professional's direction 3Ref 3Centers for Medicare & Medicaid Services (2024).Behavioral Health Integration Services.The Medicare routes that pay for non-face-to-face behavioral health work: G0323 care management and its 90791 initiating visit, 99484 general behavioral health integration, collaborative care management under 99492-99494 and G2214, the G0546-G0551 interprofessional consultation tiers and who may bill them, and the cost-sharing notice and documented verbal consent required before services begin.. Collaborative care management sits alongside it under 99492 through 99494 and G2214, on the same monthly time logic and with a larger care team behind it 3Ref 3Centers for Medicare & Medicaid Services (2024).Behavioral Health Integration Services.The Medicare routes that pay for non-face-to-face behavioral health work: G0323 care management and its 90791 initiating visit, 99484 general behavioral health integration, collaborative care management under 99492-99494 and G2214, the G0546-G0551 interprofessional consultation tiers and who may bill them, and the cost-sharing notice and documented verbal consent required before services begin..

The initiating visit is the piece easiest for a solo practice to miss. G0323's month cannot start without one, so the choice a therapist already makes at intake (90791 or 90837 for intakes) also opens or closes this route.

Before behavioral health integration services start, the billing practitioner has to tell the patient that cost sharing applies to the non-face-to-face work as well as the face-to-face work. Written consent is not required. Verbal consent is, and it has to be documented in the medical record 3Ref 3Centers for Medicare & Medicaid Services (2024).Behavioral Health Integration Services.The Medicare routes that pay for non-face-to-face behavioral health work: G0323 care management and its 90791 initiating visit, 99484 general behavioral health integration, collaborative care management under 99492-99494 and G2214, the G0546-G0551 interprofessional consultation tiers and who may bill them, and the cost-sharing notice and documented verbal consent required before services begin..

Coordination with another clinician has its own codes

When the between-session work is a conversation with another treating professional, Medicare has a purpose-built family for it. HCPCS G0546 through G0551 pay for telephone, internet or electronic health record assessment, management and referral, and they are billable by clinical psychologists, clinical social workers, marriage and family therapists and mental health counselors 3Ref 3Centers for Medicare & Medicaid Services (2024).Behavioral Health Integration Services.The Medicare routes that pay for non-face-to-face behavioral health work: G0323 care management and its 90791 initiating visit, 99484 general behavioral health integration, collaborative care management under 99492-99494 and G2214, the G0546-G0551 interprofessional consultation tiers and who may bill them, and the cost-sharing notice and documented verbal consent required before services begin.. Patient consent must be documented in the medical record 3Ref 3Centers for Medicare & Medicaid Services (2024).Behavioral Health Integration Services.The Medicare routes that pay for non-face-to-face behavioral health work: G0323 care management and its 90791 initiating visit, 99484 general behavioral health integration, collaborative care management under 99492-99494 and G2214, the G0546-G0551 interprofessional consultation tiers and who may bill them, and the cost-sharing notice and documented verbal consent required before services begin..

The codes are tiered by time, and the tiers are where a solo practice either captures the minutes or loses them.

Tiers as described in CMS's behavioral health integration booklet, MLN909432 3Ref 3Centers for Medicare & Medicaid Services (2024).Behavioral Health Integration Services.The Medicare routes that pay for non-face-to-face behavioral health work: G0323 care management and its 90791 initiating visit, 99484 general behavioral health integration, collaborative care management under 99492-99494 and G2214, the G0546-G0551 interprofessional consultation tiers and who may bill them, and the cost-sharing notice and documented verbal consent required before services begin.. The verbal and written report is part of what the descriptors describe, so a call with no note behind it is a call you cannot bill.

The AMA's own behavioral health coding resource maps professional-to-professional digital consultation to CPT 99446 through 99449 and 99451, billable by the consulting psychiatrist, with 99452 billable by the primary care professional 4Ref 4American Medical Association (2025).Behavioral health coding resource.The AMA's own map of professional-to-professional digital consultation codes (99446-99449 and 99451 billable by the consulting psychiatrist, 99452 by the primary care professional), and the absence of 90887 and 90889 from that map.. Those sit on the consulting side of the exchange, which is to say inside the solo prescriber's schedule rather than the therapist's. The same resource does not list 90887 or 90889 anywhere in its map of the behavioral health code space 4Ref 4American Medical Association (2025).Behavioral health coding resource.The AMA's own map of professional-to-professional digital consultation codes (99446-99449 and 99451 billable by the consulting psychiatrist, 99452 by the primary care professional), and the absence of 90887 and 90889 from that map..

The calls Medicare pays for on their own

Two, and both are narrow. Medicare's post-discharge follow-up contacts intervention, HCPCS G0544, is billed once per month and covers up to 4 calls, typically 10 to 20 minutes each, for patients at risk of suicide after a crisis discharge. Verbal or written consent is obtained before or during the first call 2Ref 2Centers for Medicare & Medicaid Services, Medicare Learning Network (2026).Medicare & Mental Health Coverage.The listing of 90889 as report preparation in CMS's table of commonly used mental health codes, the asterisk and dagger marks and which codes they flag, the G0544 post-discharge follow-up contacts intervention and its consent and call limits, and Medicare coverage of family psychotherapy with or without the patient present.. Nothing in it converts an ordinary between-session check-in into a billable contact.

The second is family psychotherapy. Medicare covers it with or without the patient present, as medically reasonable and necessary, with treatment of the patient as the primary purpose 2Ref 2Centers for Medicare & Medicaid Services, Medicare Learning Network (2026).Medicare & Mental Health Coverage.The listing of 90889 as report preparation in CMS's table of commonly used mental health codes, the asterisk and dagger marks and which codes they flag, the G0544 post-discharge follow-up contacts intervention and its consent and call limits, and Medicare coverage of family psychotherapy with or without the patient present.. A long conversation with a parent or a partner about the treatment plan may be family psychotherapy that happened outside the appointment slot, and coding it as coordination gives away a session.

The family psychotherapy case turns on a boundary worth keeping straight. A telehealth encounter, including audio-only sessions where the payer allows them, is a session and takes a session code. Between-session work is the time sitting outside any encounter at all, which is why it has no session code to fall back on. The same boundary shows up from the other direction around extended EMDR sessions and intensives, where the extra time sits inside the encounter and the coding problem becomes duration.

Check your own contractor before writing the time off

The lookup that answers this for your practice is the Medicare Coverage Database, searched for your own contractor's billing and coding article on psychiatry and psychology services. Article A57480 is the one carrying the incidental-services statement, with an original effective date of October 31, 2019 and a revision effective January 1, 2026 1Ref 1Wisconsin Physicians Service Insurance Corporation (Medicare Administrative Contractor), for the Centers for Medicare & Medicaid Services (2026).Billing and Coding: Psychiatry and Psychology Services (A57480).The statement that CPT 90885, 90887 and 90889 are incidental services and not separately payable, its status as one MAC's Medicare policy rather than a national rule, and the article's original and revised effective dates.. Check the revision date on whatever article you pull before quoting it to anybody.

Only that one article was confirmed as carrying the statement. Articles from other jurisdictions may read differently, so treat this as a per-contractor question you answer once, in writing, and re-answer when the article revises.

The code set moves every year, and 2026 moved it again. The CY 2026 Medicare Physician Fee Schedule final rule establishes three new G-codes billable as add-on services when the advanced primary care management base code is reported by the same practitioner in the same month, meant to be directly comparable to the existing collaborative care and behavioral health integration codes 5Ref 5Centers for Medicare & Medicaid Services (2025).Calendar Year (CY) 2026 Medicare Physician Fee Schedule Final Rule (CMS-1832-F).That CY 2026 finalized three new G-codes billable as add-on services when the APCM base code is reported by the same practitioner in the same month, comparable to the existing CoCM and BHI codes, as the anchor for how volatile this code set is.. Anything copied from a summary written two years ago is already stale on the G-code list.

But none of this reaches commercial plans. No Medicare document decides whether a commercial payer covers 90887, 90889 or a monthly care-management code, and no figure on this page is a payment amount. For a given plan, the answer lives in that plan's own published policy and in your contract with it.

Charging the client directly for the work

If the between-session work goes on the client's own bill rather than a claim, two duties attach before the first invoice. An uninsured or self-pay individual expected to receive a bill for their care gets a good faith estimate, and the binding content requirements sit at 45 CFR 149.610(c); CMS publishes a sample form, revision dated August 2023 6Ref 6Centers for Medicare & Medicaid Services (2023).Sample Good Faith Estimate for Uninsured (or Self-Pay) Individuals.That an uninsured or self-pay individual expected to receive a bill gets a good faith estimate, that CMS publishes a sample form revised August 2023, and that the binding content requirements sit at 45 CFR 149.610(c).. Name the service you intend to charge for on it.

The second duty is professional rather than legal. The 2014 ACA Code of Ethics asks a counselor to explain the nature of all services provided, and to consider the client's financial status and locality when setting fees, adjusting them where legally permissible if the usual fee creates undue hardship 7Ref 7American Counseling Association (2014).2014 ACA Code of Ethics.The ethics framing of a direct client charge for between-session work: explaining the nature of all services provided, and considering financial status and locality when setting fees, with adjustment where legally permissible if the usual fee creates undue hardship.. It binds ACA members; it is not law, and it names no dollar figure. Your own board and your own association's code may reach further.

Whether a flat administrative charge for letters, calls and coordination is permitted, and at what level, is not something the public record settles; that one is worth putting to your board and your own counsel before it appears on a fee schedule. The record does settle the disclosure: put the charge in the agreement the client signs, in the unit you will bill it in, before the first call that would trigger it.

A charge a client first meets on an invoice tends to come back as a refund request for therapy already delivered, which is a slower conversation than the one in the intake paperwork.