Top Billing Challenges for Mental Health Providers in the U.S. (and How DelonHealth Solves Them)

Keeping your practice financially healthy shouldn’t feel harder than caring for patients. Yet for psychologists, psychiatrists, LCSWs, LMFTs, PMHNPs, and group practices, billing is where time is lost, revenue leaks, and compliance risks multiply. This guide breaks down the biggest billing pain points we see across U.S. mental health practices, and the concrete ways DelonHealth helps you fix them.

Payer-by-Payer Variability (Parity in theory, ≠ parity in practice)

Even with mental-health parity rules, plans still apply different non-quantitative treatment limitations (NQTLs)—from prior authorization rules to network design—creating inconsistent coverage for the same service. Recent federal rules tighten expectations for how plans demonstrate parity on NQTLs, but practical variability remains, and it can hit reimbursement. Federal RegisterDOL

How DelonHealth helps: We maintain payer-specific rule libraries, track prior-auth/NPI quirks, and tune claims to each plan’s edits so you don’t learn the hard way via denials.

Getting Psychotherapy Codes Right (and pairing with E/M correctly)

Selecting and documenting the right psychotherapy codes—90832, 90834, 90837—plus 90791/90792 for diagnostic evaluation, and add-on psychotherapy with E/M (90833, 90836, 90838) is fundamental, but small gaps (time documentation, interactive complexity 90785, group therapy 90853) drive avoidable denials. CMS and local coverage articles spell out combinations and updates referencing E/M ranges that replaced deleted codes. Centers for Medicare & Medicaid Services+1

How DelonHealth helps: We audit notes against time/MDM, look for add-on opportunities (e.g., 90785), and align diagnosis specificity with payer policies before claims go out.

E/M Documentation After the 2021–2023 Overhauls

E/M selection now leans on time or medical decision-making (MDM) instead of history/exam checklists for most settings. Many mental-health visits qualify by time; others meet MDM. Teams still trip over the new definitions and when “total time” counts. Using E/M correctly, especially when psychotherapy is also provided, prevents under-coding and audit exposure. American Medical Associationsmfm.orgACEP

How DelonHealth helps: We standardize E/M selection logic, surface documentation gaps, and ensure psychotherapy + E/M combos (with proper add-on codes) meet guidelines.

Telehealth Rules: Permanent Flexibilities for Behavioral Health—But Nuance Matters

Good news: for behavioral and mental health, Medicare permanently allows telehealth to the patient’s home with no geographic restrictions, and even audio-only when appropriate. Non-behavioral telehealth flexibilities extend only through September 30, 2025, so it’s crucial to distinguish behavioral from other services. Pay attention to local MAC and commercial plan nuances on modifiers and place of service.

How DelonHealth helps: We configure claims with the right telehealth indicators (modifier, POS), track payer-specific rules, and keep you current as federal and commercial policies evolve.

Collaborative Care & BHI Codes: Powerful—but Underused

Many practices leave money on the table by not billing Behavioral Health Integration and Collaborative Care Model services: 99484 (general BHI), 99492–99494 and G2214 (CoCM monthly bundles). These codes reimburse the psychiatric consultant’s and care manager’s time coordinating with the treating clinician—if you meet the service elements and document correctly. Centers for Medicare & Medicaid Services 

How DelonHealth helps: We set up CoCM/BHI workflows, time tracking, and monthly roll-ups so you capture legitimate care-management revenue with clean claims.

Caregiver Training Codes (New Revenue for Family-Centered Care)

CMS activated caregiver training codes—including 96202–96203 and 97550–97552—allowing reimbursement when you train a patient’s caregiver(s) in behavior management or functional strategies, sometimes even via telehealth. Requirements are specific (e.g., group vs. individual sessions, time thresholds). Centers for Medicare & Medicaid Services 

How DelonHealth helps: We map clinical activities to the right caregiver-training code set, create time-capture templates, and apply the correct billing rules to maximize compliant reimbursement.

Medical Necessity & Time Documentation

Insurers frequently deny for “insufficient medical necessity” or missing time documentation. Notes must connect symptoms/impairments to the selected code and show start/stop or total time, modality, and treatment focus. ICD-10-CM must match the visit type and be specific. 

How DelonHealth helps: Our auditors check for time stamps, modality, goals/response, and diagnosis-to-procedure coherence before claims are submitted.

SUD Privacy (42 CFR Part 2) Meets Billing Reality

If you deliver substance-use-disorder services (or co-treat), 42 CFR Part 2 rules govern how records can be used and disclosed for payment and operations. The 2024 final rule aligns certain Part 2 provisions with HIPAA and allows a single consent for future uses/disclosures, but compliance deadlines and redisclosure constraints still require care—especially with multi-payer claims and vendor access. HHS.govFederal RegisterNetwork for Public Health Law

How DelonHealth helps: We implement minimum-necessary data sharing, consent tracking, and BAAs aligned to Part 2/HIPAA, so billing doesn’t create a privacy incident.

Prior Authorizations, Coverage Limits & Session Caps

Many plans use NQTLs like session caps, step therapy, or prior auth for higher-intensity services (e.g., 90837, IOP, PHP). The latest parity rules put more scrutiny on these restrictions, but practices still need tight workflows to verify benefits, obtain authorizations, and update treatment plans to meet “medical necessity” criteria. Federal RegisterDOL

How DelonHealth helps: Front-end benefits checks, streamlined PA submissions, and prompts when you’re nearing utilization limits—so care and cash flow aren’t interrupted.

Credentialing, Contracting & Rate Management

Delays in credentialing your clinicians (or updating a taxonomy/address) can stall weeks of billing. Contract terms vary widely—even inside one carrier across product lines—affecting rates, timely filing, EFT/ERA, and appeal windows.

How DelonHealth helps: We handle payer enrollment, CAQH updates, EFT/ERA setup, and contract data management, then push alerts for renegotiation opportunities.

Denial Management & Appeals You Can Win

Common denial reasons: diagnosis mismatch, missing time/modifiers, place-of-service errors for telehealth, “not a covered benefit,” or late filing. Many are recoverable with corrected claims or appeals that cite payer policy, parity rules, or CMS guidance.

How DelonHealth helps: We categorize denials by root cause, fix upstream documentation/coding, and send targeted appeals with evidence—raising net collections and lowering days in A/R.

Multi-State Telehealth & Licensure Nuances

If your clinicians see patients across state lines, licensure and payer enrollment must match the patient’s location at the time of service. The billing address, POS, and modifiers must reflect the telehealth scenario accurately (e.g., POS “10” home vs. “02” telehealth other), and commercial plans can differ from Medicare.

How DelonHealth helps: We verify licensure/enrollment alignment, set correct POS/modifiers by payer, and prevent cross-state claims from auto-denying.

Choosing the Right Modifiers & POS for Telehealth

Behavioral health often needs modifier 95 and a proper place of service (frequently 10 – patient’s home). Some MACs and commercial plans have unique lists or prefer different combinations. Getting this wrong creates instant denials.

How DelonHealth helps: We maintain a payer-specific telehealth matrix and apply rules automatically in claim creation.

Under-Billing Group, Family, or Crisis Services

Codes like 90853 (group), 90846/90847 (family), and crisis psychotherapy 90839/90840 require specific documentation elements (time, who was present, clinical focus). Under-utilization or incomplete notes lead to lower revenue or denials.

How DelonHealth helps: We supply note templates keyed to each service, validate elements pre-submission, and track utilization so you code what you actually do.

Under-Leveraging Integrated Care Revenue

Primary-care partnerships using CoCM/BHI (and FQHC/RHC equivalents G0511/G0512) can transform access and revenue, but many behavioral practices don’t operationalize them or miss the initiating visit, consent, time, and monthly elements required for payment. American Medical Association

How DelonHealth helps: We set up the workflows, time capture, roster management, and monthly attestation so you bill confidently and compliantly.

Keeping Up with Annual Fee-Schedule & Policy Changes

From conversion-factor shifts to code-status changes (e.g., G2211 activation) and evolving telehealth lists, yearly rules affect both allowables and documentation. Falling behind means under-billing or avoidable payer take-backs. Holland & Knight

How DelonHealth helps: We push change summaries, update your fee schedules, and tune claim logic (codes, modifiers, POS) before the new year flips.

Best-Practice Checklist for Mental Health Billing

Front desk/intake

• Verify eligibility/benefits at scheduling; capture telehealth consent and preferred setting (home vs. other).
• Pre-screen for prior auth and session caps; set reminders before limits are reached.

Clinical documentation

• Tie symptoms/impairments to medical necessity.
• Capture time for time-based psychotherapy; note modality (e.g., CBT), goals, and patient response.
• For psychotherapy + E/M: document both components; use appropriate add-on code.
• For group/family or crisis services: clearly note participants, time, and focus.
• For CoCM/BHI: create the initiating visit, consent, and monthly elements (care manager time, psych consultant input).

Coding & claims

• Pick correct CPT/HCPCS, modifiers (e.g., 95), and POS (often 10 for home telehealth).
• Use G2211 when longitudinal complexity applies and exclusions don’t.
• Consider caregiver-training codes (96202–96203, 97550–97552) when you train caregivers.

Compliance & privacy

• Apply 42 CFR Part 2/HIPAA rules to SUD records and redisclosures.
• Maintain payer policy archives and parity-rule awareness for appeals.

Revenue cycle

• Post payments/ERAs daily; work denials weekly.
• Trend denials by reason/payer/clinician; fix root causes (templates, training, payer setup).
• Reconcile A/R; monitor days-sales-outstanding and net collection rate.

Why DelonHealth

DelonHealth is a dedicated mental-health RCM partner built for solo practices, multi-clinician groups, and hybrid (in-person + telehealth) models. We handle:

• Eligibility & prior auth: automated checks, payer-specific workflows.
• Clinical documentation support: time prompts, evidence-based note templates, and pre-submission audits.
• Coding & charge capture: psychotherapy + E/M combos, G2211 logic, CoCM/BHI monthly bundles, caregiver training, and crisis services.
• Telehealth billing: correct modifiers/POS per payer; behavioral-health-specific rules.
• Compliance: 42 CFR Part 2 + HIPAA controls for claims data and redisclosure.
• Denials & appeals: fast reworks with parity and policy citations; root-cause elimination.
• Analytics: dashboards for A/R, denial rates, top CPTs, payer mix, and under-coded opportunities.
• Credentialing/contracting: CAQH, EFT/ERA, fee schedules, and renegotiation support.

Outcome: higher clean-claim rate, fewer write-offs, and more time for patient care.

Frequently Asked Questions (Quick Answers)

Is audio-only telehealth still billable?
Yes, permanently for Medicare behavioral/mental health in the patient’s home, with no geographic restrictions. Commercial plans vary; we configure per payer.

Do parity rules change denials?
They can strengthen appeals against restrictive NQTLs (e.g., burdensome prior auth), but you still need payer-specific evidence and proper documentation. Federal Register

Ready to Stop Revenue Leaks?

If your team is wrestling with denials, under-coding, or telehealth confusion, DelonHealth can step in with a billing tune-up, a full RCM partnership, or a clean-claim sprint to improve cash flow fast.

Let’s talk. Share your top two pain points, and we’ll send a targeted remediation plan—plus a sample documentation template for 90837, CoCM monthly billing, or caregiver training.

About DelonHealth
DelonHealth provides end-to-end RCM and medical billing for mental-health practices across the U.S.—including eligibility, coding, telehealth billing, Part 2/HIPAA-aware workflows, denials/appeals, and data-driven revenue optimization. Let’s turn complex billing into clean claims and predictable cash.

Contact Us

Email: info@delonhealth.com

Website: https://delonhealth.com/