Reviewed by Roey Hine
Key Takeaways
- Psychotherapy for crisis is billed with 90839 for 30 to 74 minutes and 90840 for each additional 30 minutes, and it cannot be combined with most other psychiatric codes on the same day.
- Medicare pays crisis psychotherapy furnished in non-office, non-facility settings such as a patient’s home through G0017 and G0018, at 150% of the fee schedule amount.
- Family psychotherapy uses 90846 without the patient and 90847 with the patient, and Medicare covers it when the primary purpose is treating the patient’s condition.
- Interactive complexity (90785) requires one of four specific communication factors and does not apply to translation alone, crisis psychotherapy, or family psychotherapy.
- Medicare pays for multiple mental health services on the same day but not duplicate ones, and several code pairs are barred outright.
Most behavioral health claims use a handful of time-based psychotherapy codes. The sessions that fall outside that pattern, such as a patient in acute crisis, a family session with or without the patient, or a visit complicated by an interpreter or a caregiver’s behavior, carry separate codes with their own time rules and same-day restrictions.
Which Codes Cover Crisis, Family, and Interactive Complexity Services?
Eight codes cover these services. The time rules below come from CMS and from the psychotherapy payment policy of Blue Cross and Blue Shield of Oklahoma (BCBS Oklahoma), which restates CPT reporting rules.
| Code | Service | Time or reporting rule |
| 90839 | Psychotherapy for crisis, first 60 minutes | Reported for 30 to 74 minutes of crisis psychotherapy, once per day |
| 90840 | Psychotherapy for crisis, each additional 30 minutes | Add-on to 90839 for time beyond 74 minutes |
| G0017 | Psychotherapy for crisis in an applicable site of service, first 60 minutes | Medicare code for non-facility settings other than the office |
| G0018 | Psychotherapy for crisis in an applicable site of service, each additional 30 minutes | Add-on to G0017 |
| 90846 | Family psychotherapy without the patient present | 50 minutes, with at least 26 minutes required |
| 90847 | Family psychotherapy with the patient present | 50 minutes, with at least 26 minutes required |
| 90849 | Multiple-family group psychotherapy | Per session |
| 90785 | Interactive complexity add-on | Added to an eligible primary code when a qualifying communication factor is present |
When Does a Session Qualify as Psychotherapy for Crisis?
A session qualifies as psychotherapy for crisis when the patient presents with an urgent problem that requires immediate assessment and treatment. CPT defines the service as including:
- An urgent assessment and history of the crisis state
- A mental status exam
- Psychotherapy, mobilization of resources to defuse the crisis and restore safety, and psychotherapeutic interventions to minimize the potential for psychological trauma
- A disposition
Crisis psychotherapy of 30 to 74 minutes on a date of service is reported once with 90839, and time from 75 minutes onward is reported with 90840 in 30-minute units. Sessions under 30 minutes are reported with the standard time-based psychotherapy code instead. CMS counts all crisis time spent with the patient on the date of service, even when it is not continuous, so a crisis that resumes later in the day adds to the same total.
Documentation should show each required element, the start and stop times for every segment, and the safety plan or disposition. A note that describes a difficult session without the assessment, mental status exam, and disposition supports a standard psychotherapy code, not a crisis code.
What Are G0017 and G0018?
G0017 and G0018 are Medicare HCPCS codes for psychotherapy for crisis furnished in an applicable site of service, defined as any place of service where the non-facility rate for crisis psychotherapy applies, other than the office. Settings such as a patient’s home qualify. G0017 covers the first 60 minutes and G0018 each additional 30 minutes, and both took effect January 1, 2024.
According to CMS, payment for these services is 150% of the fee schedule amount for non-facility sites. Crisis psychotherapy delivered in an office, hospital, or other facility setting continues to use 90839 and 90840.
What Cannot Be Billed With Crisis Psychotherapy on the Same Day?
CMS instructs practitioners not to bill the crisis codes with psychiatric diagnostic evaluations (90791, 90792), the standard psychotherapy codes (90832-90838), or other psychiatric services in the 90785-90899 range. That range includes interactive complexity, family psychotherapy, and group psychotherapy. If a full diagnostic evaluation is also needed, it is reported on a separate date of service.
How Do You Bill Family Psychotherapy?
Family psychotherapy uses 90846 when the patient is not present and 90847 when the patient is present. Both describe 50-minute sessions, and BCBS Oklahoma’s policy requires at least 26 minutes of service. Multiple-family group psychotherapy, in which several families meet together, uses 90849.
Medicare covers family psychotherapy with or without the patient present when the primary purpose is treatment of the patient’s condition, according to CMS’s Medicare & Mental Health Coverage booklet. Sessions focused on a family member’s own mental health needs do not meet that standard. Contractors also apply presence rules for 90847: CGS, a Medicare Administrative Contractor, requires the patient to be present for all or part of the session.
BCBS Oklahoma allows family and individual psychotherapy for the same patient on the same day when the services are separate and distinct. Documentation should show distinct times and content for each session.
When Does Interactive Complexity (90785) Apply?
Interactive complexity is an add-on code for sessions in which a specific communication factor complicates delivery of the primary service. According to the American Psychiatric Association’s interactive complexity guide, at least one of four factors must be present during the visit:
- The need to manage maladaptive communication among participants, such as high anxiety, high reactivity, repeated questions, or disagreement
- Caregiver emotions or behaviors that interfere with implementing the treatment plan
- Evidence or disclosure of a sentinel event and a mandated report to a third party, with discussion during the visit
- Use of play equipment, physical devices, an interpreter, or a translator to overcome barriers with a patient who has not developed, or has lost, the expressive or receptive language skills to communicate
Code 90785 can be added to psychiatric diagnostic evaluations (90791, 90792), psychotherapy (90832, 90834, 90837), the psychotherapy add-ons reported with E/M (90833, 90836, 90838), and group psychotherapy (90853). It cannot be added to crisis psychotherapy, family psychotherapy, or an E/M visit without psychotherapy. CMS has stated that 90785 generally should not be billed solely for translation or interpretation. BCBS Oklahoma’s policy adds that a difficult session does not automatically qualify and that the code does not report extra time. The note should name the specific factor and describe how it affected the session.
Which Behavioral Health Services Can Be Billed on the Same Day?
Medicare pays for multiple mental health services for the same patient on the same day, furnished by the same or different professionals in the same or different locations, but it does not pay for duplicate services. Common same-day restrictions include:
- Crisis psychotherapy with diagnostic evaluations, standard psychotherapy, or other psychiatric services
- Diagnostic evaluation with psychotherapy. Medicare contractors generally do not allow 90791 or 90792 with a psychotherapy code for the same patient on the same day.
- E/M with a standalone psychotherapy code. When a prescriber provides medication management and psychotherapy in one visit, the psychotherapy is billed with an add-on code (90833, 90836, or 90838) next to the E/M code.
- Interactive complexity with an ineligible primary code, such as crisis or family psychotherapy
- Overlapping time, such as the same minutes counted toward both an individual and a family session
The E/M and add-on rules are covered in PGM’s breakdown of the coding and billing mistakes behind denied behavioral and mental health claims. These conflicts can be caught before submission with a claim scrubber that applies code-pair edits. For local or national policies that affect same-day billing, CMS directs practices to their Medicare Administrative Contractor’s website.
Who Can Bill Crisis and Family Psychotherapy Under Medicare?
CMS lists physicians, clinical psychologists, clinical social workers, clinical nurse specialists, nurse practitioners, physician assistants, certified nurse-midwives, marriage and family therapists, and mental health counselors as practitioners who can bill psychotherapy for crisis. Marriage and family therapists and mental health counselors have been able to enroll and bill Medicare independently since January 1, 2024.
How PGM Supports Crisis and Family Therapy Billing
PGM has provided independent medical billing and revenue cycle management since 1981, with dedicated support for mental and behavioral health practices. Services include eligibility and benefits verification, prior authorization support, coding review, claims submission, denial management and appeals, and payment posting and reporting across commercial, Medicare, and Medicaid payers.
If crisis, family, or same-day claims are denying, talk to PGM’s behavioral health billing team. For what to expect from a specialized partner, see our post on how to choose a behavioral health billing company.
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Frequently Asked Questions About Crisis, Family, and Interactive Complexity Billing
Can crisis psychotherapy be furnished through telehealth?
Yes. CMS permits psychotherapy for crisis through telehealth when all Medicare telehealth requirements are met. Place-of-service codes and modifiers for telehealth claims vary by payer, as covered in PGM’s post on telehealth versus in-office mental health billing.
Does a therapy session with a child automatically qualify for interactive complexity?
No. The patient’s age does not qualify a session on its own. One of CPT’s four qualifying factors must be present, such as play equipment used to communicate with a child who cannot yet describe symptoms in words, or a parent’s behavior that interferes with carrying out the treatment plan.
Whose diagnosis and coverage go on a family psychotherapy claim?
The identified patient’s. Family psychotherapy is billed as treatment of the patient’s condition, so the claim carries the patient’s diagnosis and is submitted to the patient’s coverage, including for 90846 sessions in which the patient is not present.
How many units of 90840 can be billed in one day?
Code 90839 is reported once per day. Code 90840 adds one unit for 75 to 104 total minutes, two units for 105 to 134 minutes, and one more for each further 30 minutes. A 90-minute crisis session, for example, is reported as 90839 plus one unit of 90840.