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A communication log or portal message note documents a client contact that happens outside a scheduled session: a patient portal message, phone call, text, or secure email. Therapists, psychologists, and practice teams use it to record what was communicated, their clinical read of it, and the follow-up. Most entries run 50 to 200 words; a billed e-visit entry runs longer.
Therapists, psychologists, counselors, psychiatrists, and practice staff triaging messages under a supervising clinician
Treating clinician and practice team; payers and auditors when a contact is billed; clients can read messages through access rights
50 to 200 words · 2 to 5 minutes by hand (clinical team estimate)
Brief operational chart entry (compare: care coordination note, billing note, crisis note)
After any material out-of-session contact: portal messages, phone calls, texts, secure email
A professional convention, not a named legal form; messages sit in the designated record set, and billed digital services carry payer-specific rules
A communication log, also called a portal message note, phone note, or telephone encounter, is the chart entry for a client contact that happens outside a scheduled session: a patient portal message, a phone call, a text, or a secure email. It records that the contact happened, what was clinically material in it, and how you handled it. Unlike the SOAP note, which traces to Lawrence Weed's problem-oriented medical record, this document type has no inventor, no founding publication, and no standards body. It is the meeting point of two separate streams: billing documentation expectations that arrived when the CPT 2020 code set created e-visit codes for patient-initiated digital exchanges, and licensing-board record-keeping standards that require material between-session contacts to be documented. Most of its names come from EHR vendors: telephone encounter and in-basket message from Epic, MyChart message, secure message note, virtual check-in note.
Two boundaries keep the log honest. It is not a progress note: the progress note documents the session, the communication log documents the space between sessions, and a billed e-visit sits in between, a communication entry that must also carry decision-making and time. And no law requires a separate note for every call or text; what United States law actually says is narrower and stronger. Portal messages and documented calls that inform decisions about a client sit inside the HIPAA designated record set (45 CFR 164.501), which makes them reachable by the client's right of access and, as electronic health information, subject to the information blocking rule. The famous exclusion is narrower than practitioners hope: psychotherapy notes means separately kept process notes, not routine messages about symptoms, scheduling, or medication, so the working assumption is that anything you type to or about a client can one day be read by them.
Any practice with a portal, a phone line, or a texting policy produces these entries, and the volume keeps climbing: an Epic Cosmos analysis of roughly 8 billion encounters found patient-authored portal messages rose 153 percent from 2020 to 2025, to 2.5 messages per active patient per year, while office visits rose 17 percent, so messaging arrives on top of session work, not instead of it. Telehealth-forward and asynchronous practices lean on the log hardest, and front-desk or clinical staff often write the first entry when they triage the inbox under a supervising clinician. The boundaries matter more than the format: a provider-to-provider exchange belongs in a care coordination note, a contact that becomes active risk work belongs in a crisis note, and an exchange you intend to bill has to double as a claim-support record.
Date, time, mode, and initiator. When the contact happened, through what channel (portal, phone, text, secure email), and who started it. Patient initiation is a billing prerequisite for e-visit and virtual check-in codes, so record it even when you have no plan to bill. Pitfall: an entry with no initiator. A log that is silent on who started the exchange can never support a billed digital service later, and it hides the difference between outreach and response.
Participants and identity. Who was on each end, and how you knew. A portal message arrives through an authenticated login; a phone call does not, so note how you confirmed you were talking to your client, and name any third party who relayed information. Pitfall: a relative's call logged as the client's own report. When a parent or partner calls about the client, the entry is a collateral contact and should say so, which also keeps later release decisions clean.
Substance of the contact. The clinically material content: what was reported, asked, or disclosed. Quote sparingly and summarize the rest. If the message thread stays in the EHR, no regulation requires re-typing it; the thread can itself be the record, and the log entry adds the clinical handling. Pitfall: both extremes. Re-transcribing a thread that is already retained wastes hours, and the bare 'spoke with client' fails the adequate-records standard licensing boards apply.
Clinical assessment and risk. What you made of it. If the contact conveyed symptoms, side effects, or risk, the entry should show your judgment: what changed, what did not, and whether screening or a safety response was indicated. Pitfall: advice with no reasoning. This section also decides billing: an exchange with no medical decision-making cannot be billed as an e-visit, however long it took.
Action taken and follow-up. Advice given, changes made, scheduling, referral, escalation, and who does what by when. Close the loop the message opened, and note any resulting appointment. Pitfall: 'will follow up' with no owner or date. The resulting visit matters too: an exchange that leads to a visit within 24 hours, or follows a related one within 7 days, is bundled into that visit rather than separately billable.
Billing status, time, and consent. Most entries end with 'not billed', and writing that is protective, not risky. When you do bill, the entry has to carry the claim: the code, time spent, cumulative time across the rolling 7-day window that selects among the e-visit codes, and consent for digital services, which Medicare lets you obtain verbally once a year. Pitfall: reaching for deleted codes. The physician telephone codes 99441 to 99443 ended January 1, 2025; the nonphysician telephone codes 98966 to 98968 remain active, and Medicare prices the nonphysician e-visit codes 98970 to 98972 at zero.
Signature and authentication. Author name, credentials, and date, with cosignature where supervision rules require it. Staff can and should document their own triage under their own logins. Pitfall: a staff-handled exchange billed as a clinician service. Billed e-visits and virtual check-ins require the billing practitioner's own interaction with the client; a message answered entirely by staff is documentation, not a billable service.
COMMUNICATION LOG / PORTAL MESSAGE NOTE
(out-of-session contact; a session gets a progress note instead)
Client: [initials] DOB: __________ Date: ____________
Time: ________ Mode: [ ] portal [ ] phone [ ] text [ ] email
Initiated by: [ ] client [ ] clinician [ ] staff [ ] other: _____
Participants / identity confirmed by: _____________________________
SUBSTANCE OF CONTACT (summarize; the retained thread can be the record)
___________________________________________________________________
___________________________________________________________________
CLINICAL ASSESSMENT / RISK (required if symptoms or risk were conveyed)
___________________________________________________________________
___________________________________________________________________
ACTION TAKEN / FOLLOW-UP (advice, scheduling, referral; owner and date)
___________________________________________________________________
___________________________________________________________________
BILLING STATUS
[ ] Not billed (documentation only)
[ ] Billed: code ________ Time this contact: ______ min
Cumulative time, rolling 7 days (e-visits): ______ min
Digital-service consent on file: [ ] yes Date: ________
Related visit within prior 7 days / next 24 hours: [ ] no [ ] yes
Author (name / credentials): ____________________ Date: ________
Supervisor cosign (if required): ________________ Date: ________Free to use and share, no signup. The PDF includes a one-page cheat sheet with section-by-section pitfalls and a pre-sign checklist; the DOCX is the blank template, ready to adapt.
Scenario: an established psychotherapy client sends a patient portal message between weekly sessions; the psychologist replies the same day and logs the contact without billing it. All details are fictional.
Communication log. Portal message · Client: D.K., 41 · Date: 07/21/2026 · Time: 2:15 PM · Initiated by: client (authenticated portal account)
Substance: Client messaged at 11:52 AM: "Rough week at work and the breathing exercise isn't cutting it. Can we get to the sleep piece sooner?" Full thread retained in the EHR message center; no attachments.
Assessment / risk: Message reports increased work stress and early-week insomnia, consistent with the existing generalized anxiety presentation; no new symptoms and no medication questions. No risk content in the message; client denied ideation at the 07/17/2026 session, and nothing here changes that screening. No urgent response indicated.
Action taken / follow-up: Replied through the portal at 2:15 PM: validated the stress, coached one adjustment to the paced-breathing cadence, and moved the sleep module up to the next session. Offered an earlier appointment; client confirmed Thursday 07/23/2026 at 3:00 PM, replacing the standing Friday slot. Agenda flag added to the appointment.
Billing status: Not billed; brief supportive reply inside the existing treatment plan (6 minutes; the practice does not bill portal messages). Digital-communication consent on file 01/12/2026. No related visit inside the billing windows either way; noted for completeness.
Authentication: L. Moreno, PsyD. Entered 07/21/2026, 2:24 PM. No cosign required.
This sample is fictional and for educational purposes. It does not describe a real client or practice.
Writing these after every session? BastionGPT drafts complete notes from bullets, dictation, or a transcript.
Generate a note from bulletsPortal messages and documented calls are not a private side channel. Whenever they are used to make decisions about a client, they sit inside the HIPAA designated record set (45 CFR 164.501), the client's right of access reaches them (45 CFR 164.524), and their content is electronic health information under the information blocking rule (45 CFR Part 171), where unreasonable withholding carries consequences. The psychotherapy-notes carve-out will not rescue a routine message: that exclusion covers separately kept process notes, not scheduling, symptom, or medication exchanges (the psychotherapy notes authorization page covers the narrow category that does get special handling). Texts that carry clinical content are in the record set regardless of whose device they sit on, which is a Security Rule problem worth solving with policy before it becomes one. On retention, HIPAA's famous 6-year rule applies to compliance documentation such as policies and risk analyses, not to clinical records; how long you keep messages and logs is set by state law in the US and by provincial, state, and territory law in Canada and Australia, where common answers run 7 to 10 years and longer for minors.
When a between-visit exchange is billed, the log entry doubles as the claim-support record, and the payer rules are specific: a patient-initiated exchange with an established client, medical decision-making in your reply, time accumulated across a rolling 7-day window, no related visit in the 7 days before, none generated in the 24 hours after, and digital-service consent documented annually. Denials arrive as bundling (CO-97: the payment sits inside another service) or as non-coverage (CO-96 with remark N448 for codes a fee schedule never pays, which is where Medicare puts the nonphysician e-visit codes). The billed message is the exception, not the rule: UCSF billed under 2 percent of patient messages after turning message billing on, and other large systems report under 1 percent. For everything else the format is a convention and the content is the requirement: date, initiator, substance, your handling, and follow-up, at whatever length the contact deserves. The claim-support billing note covers the billed case in detail, and a scheduled video session is not a between-visit contact at all: document it as a telehealth session note.
Between-visit services are audited as telehealth, and the findings are documentation findings. In one HHS Office of Inspector General national sample, 31 of 100 telehealth claims failed Medicare requirements, an estimated $3.7 million in avoidable spending for the audit period. The Massachusetts state auditor found MassHealth paid at least $91.8 million for telehealth behavioral health services that were not properly documented, with every one of the 47 sampled claims carrying at least one documentation defect. And a 2024 OIG review of $1.4 billion in telehealth E/M payments listed the failures reviewers always list: no record at all, illegible entries, and detail too thin to support the service billed. The BastionGPT Clinical Advisory Board sees the same errors most often in communication log reviews:
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See how clinicians use it day to day on the AI therapy notes page.
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No law in the US, Canada, or Australia requires a note for every contact. What licensing boards require is adequate records, and adequacy runs on materiality: the College of Psychologists of Ontario expects the date of every material consultation to be recorded, and the Psychology Board of Australia's code of conduct, in force since December 2025, requires accurate, factual records that report relevant details. A scheduling text needs no clinical note. A message that carries symptoms, risk, or a treatment decision does. Write your messaging boundaries into the informed-consent paperwork and the judgment calls get easier.
Sometimes, inside strict rules. Clinicians who can report E/M services, including clinical psychologists, can bill the e-visit codes 99421 to 99423 when an established client initiates the exchange, the reply involves medical decision-making, and time accumulates across a rolling 7-day window, with no related visit in the prior 7 days and none generated within 24 hours after. Purely administrative replies never qualify. The scale is worth knowing: after UCSF turned on message billing, billed e-visits rose nearly fivefold yet stayed under 2 percent of messages received. In Canada, psychologists have no public payer for this, and in Australia there is no MBS item for asynchronous psychology messaging. The claim-support billing note covers what a billed entry must carry.
In the US, yes. Messages and call records used to make decisions about a client are part of the HIPAA designated record set under 45 CFR 164.501, the right of access in 45 CFR 164.524 reaches them, and their content is electronic health information under the information blocking rule. The psychotherapy-notes exclusion is narrow: separately kept process notes analyzing a session, not routine messages about symptoms, scheduling, or medication. The psychotherapy notes authorization page covers the one category that does get special handling. A message you would not want read back is a message to handle in session instead.
No regulation in the US, Canada, or Australia says a thread must be re-transcribed. If the portal thread is retained in the EHR, the thread itself is part of the record, and the better log entry is short: point to the thread, summarize what mattered clinically, and record your assessment and action. Re-typing conversations adds hours and no defensibility. The exception is content that lives outside the chart, such as texts on a personal phone: get the clinical substance into the record, because it belongs to the designated record set wherever it sits.
Document the material content, your risk assessment, and the action you took, at the time you took it: what the client reported, what you evaluated, who you contacted, and the plan you landed on. If the contact turned into active risk work, a crisis note carries it better than a brief log entry, and any safety plan you build or revise is its own document. Then close the loop in your communication policy: clients should know from intake that messages are not monitored around the clock and where to turn urgently instead.
The physician telephone codes 99441 to 99443 were deleted effective January 1, 2025, and many pages still list them as current. Still active: the nonphysician telephone codes 98966 to 98968, the e-visit codes 99421 to 99423 for clinicians who can report E/M, and the nonphysician e-visit codes 98970 to 98972, which Medicare prices at zero but some Medicaid programs and commercial plans pay. Of the telemedicine code family 98000 to 98016 created for 2025, Medicare recognizes only 98016, the virtual check-in that replaced G2012. Codes move; verify against the current year's fee schedule before promising anyone reimbursement.
Follow who is on the other end. Client or family on the other end: communication log. Another provider or agency on the other end: care coordination note, which documents referrals, handoffs, and what was shared under which consent. Ongoing between-visit care management with monthly time tracking belongs in a chronic care management note, and a contact that becomes risk work belongs in a crisis note. The communication log is the patient-facing member of the family.
Longer than HIPAA says, because HIPAA does not say. Its 6-year rule covers compliance documentation such as policies and risk analyses, not clinical records or message content. Retention comes from state, provincial, and territory law: US states vary widely, Canadian provinces commonly expect 10 years from last contact or from a minor reaching the age of majority, and Victoria, New South Wales, and the ACT require 7 years from last service or until a client who was a minor turns 25. If a message informed care, it keeps for as long as the chart it belongs to.
Yes. Paste a portal thread, describe a phone call, or dictate what happened, and it drafts the entry with the date, mode, initiator, substance, assessment, and follow-up in place, then checks it for the details that decide billability when you plan to bill. BastionGPT is HIPAA-compliant with a signed BAA on every plan, and your data is never used to train models.
Educational content, not legal or billing advice. Sample notes are fictional. Follow your organization's policies and your board, payer, and jurisdiction requirements.