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A DAP note is a three-part progress note format that organizes a therapy session into Data, Assessment, and Plan. It merges SOAP's Subjective and Objective material into a single Data section, which suits the more qualitative flow of psychotherapy documentation. A typical therapy DAP note runs 150 to 300 words.
Therapists, counselors, psychologists, community and solo behavioral health clinicians
Treating clinician, care team, supervisors, payers, auditors
150 to 300 words · 10 to 20 minutes by hand (clinical team estimate)
Structured progress note (compare: SOAP, BIRP, PIE; DARP adds a Response section)
After each individual, couples, group, or telehealth session
A documentation convention, not a mandated form; law and payers regulate the record's content, not its headings
DAP stands for Data, Assessment, Plan. It is a three-part progress note format that merges SOAP's Subjective and Objective material into a single Data section, then keeps Assessment and Plan. That merge is the point: psychotherapy sessions rarely split cleanly into "what the client said" and "what you measured," and DAP lets the session's material flow into one place. DAP appears to be a behavioral-health adaptation of the SOAP note and the problem-oriented medical record tradition behind it; no standards body or original publication established DAP as a formally standardized type, and no law or payer manual we reviewed requires the Data, Assessment, Plan headings by name. A common variant is the DARP note, which adds a Response section for the client's reaction to interventions.
The legal footing matters more than the headings. A DAP note that contains diagnosis, treatment-plan content, symptoms, progress, or session timing is a progress note in the standard clinical record, not a HIPAA "psychotherapy note": HHS's definition expressly excludes exactly those items. Keep private process reflections in separately maintained psychotherapy notes with their own authorization rules.
DAP is the default in much of behavioral health: solo therapists, counselors, community mental health teams, and group practices whose documentation is more qualitative than medical. It works well when your notes are read mostly inside your own practice. When records routinely travel to integrated or multidisciplinary settings, SOAP is often preferred because payers and medical teams already know how to read the subjective/objective split. Choose DARP when you want the client's response to interventions separated from the plan, and BIRP when documenting intervention and response as distinct fields matters operationally. No payer or regulator we reviewed requires one of these formats over another; what they regulate is whether the record supports the service.
Each section in more detail, with the pitfall that most often undermines it:
D: Data. The merged record of what was reported, observed, measured, and done. Include at least one observable or score (PHQ-9, GAD-7, SUDS) and name the interventions you actually delivered. Pitfall: Data that is all narrative with nothing observable or measurable behind it, or therapy time missing when a time-based code is billed.
A: Assessment. Interpretation, not repetition: what the data means for diagnosis, functioning, and progress toward a numbered treatment-plan goal, plus risk status. Pitfall: restating the Data section instead of interpreting it, which breaks the medical-necessity chain payers look for.
P: Plan. Specific and dated next steps: interventions, homework, referrals, coordination, next appointment. Pitfall: a bare "continue treatment" with nothing the next note can evaluate.
Client: [initials] Date: Session #: Service: [type/length] Start/stop or total time: D (Data): A (Assessment): P (Plan): Clinician signature/credentials: Date signed:
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: adult client, panic disorder, CBT with interoceptive exposure, session 5 of a planned 12, delivered by telehealth. All details are fictional.
Client: R.S., 29 · Date: 07/10/2026 · Session: 5 · Service: Individual psychotherapy, 45 min, telehealth video; client at home, in state; consent on file · Start/stop: 09:01 to 09:46
D: Client reported two panic episodes this week, down from four, both managed without leaving the situation. Panic log completed 6 of 7 days. On video: engaged, speech normal rate, affect mildly anxious when discussing an upcoming flight. Reviewed log entries together. Conducted interoceptive exposure (straw breathing, three trials; peak SUDS 65 falling to 40 by trial three) and cognitive reframing of "a racing heart means something is wrong with me," with evidence review. Denied suicidal ideation and self-harm urges.
A: Panic frequency and duration improving; client is applying skills between sessions and tolerated exposure trials with decreasing distress, consistent with Goal 1 of the treatment plan (reduce panic frequency and situational avoidance). Willingness to plan the flight suggests reduced avoidance. Symptoms remain consistent with panic disorder, improving. Risk: denies ideation; no risk indicators observed; continue routine monitoring.
P: Continue weekly CBT with interoceptive exposure. Homework: one straw-breathing trial daily, continue panic log. Begin flight-preparation exposure hierarchy next session. Re-rate symptom measures at session 8. Next appointment 07/17/2026.
This sample is fictional and for educational purposes. It does not describe a real patient.
Writing these after every session? BastionGPT drafts complete notes from bullets, dictation, or a transcript.
Generate a note from bulletsA DAP note is part of the designated record set: clients can request it, payers can audit it, and other providers may rely on it. Keep private process reflections in separately maintained psychotherapy notes with their own authorization rules. For couples, family, and group work, two rules travel well: each participant needs documentation that can stand alone, and access is not all-or-nothing. Ontario's psychotherapy college, for example, releases a joint record in full only when all participants consent; a single requester is entitled to their own information plus communal content that is not attributable to another participant (see family and couples and group notes).
On billing, the sharpest open question is time documentation, and the official guidance is genuinely mixed: Medicare's current billing article for psychotherapy services accepts start/stop times or total time when time is relevant to the code, while an older contractor fact sheet says exact times must be documented. In that environment, recording start and stop times remains the most audit-defensible choice. Authentication matters just as much: in a provider-level OIG audit, all 100 sampled beneficiary days failed Medicare requirements, with missing psychotherapy time, absent treatment notes, and unsigned treatment plans among the findings.
On retention, HIPAA does not set a patient-chart period: HHS says state law generally governs. Ontario colleges use a 10-year floor (longer for minors). In Australia, Better Access adds two program rules generic DAP pages miss: a written report to the referrer at the completion of each course of treatment, and a requirement to keep referrals for two years from the first MBS service under that referral.
Audit findings are about content, not the choice of DAP over SOAP. In Medicare's 2024 reporting-period data for outpatient psychiatric services, 16.1% of payments were improper, a projected $254.5 million, with insufficient documentation driving 78.3%. A national OIG audit estimated $580 million in improper psychotherapy payments, and in one provider-level audit, 100 of 100 sampled beneficiary days were noncompliant. The BastionGPT Clinical Advisory Board sees the same patterns most often in DAP note reviews:
| Aspect | United States | Canada | Australia |
|---|---|---|---|
| Status | Convention: no law or payer manual requires the DAP headings; HIPAA governs the record's privacy status and payers govern documentation support | Convention; Ontario college standards (CRPO, CPBAO) make record content and access enforceable | Convention; Psychology Board Code of Conduct (from 1 Dec 2025) and Ahpra expectations govern record quality |
| Terminology | DAP note, DAP progress note, DARP (adds Response) | Clinical record, session note | Case note, session note |
| What changes | Time support for billed codes, signatures, treatment-plan linkage | Ontario: progress notes may be kept in the therapy language (key info in English or French); joint-record access is severable, not all-or-nothing | Better Access: written report to the referrer after each course of treatment; keep referrals 2 years from the first MBS service |
| Retention | No HIPAA chart rule; state law and payer contracts govern | Ontario: at least 10 years from last interaction, or from the client's 18th birthday | 7 years since last entry; until age 25 for clients under 18 (Psychology Board Code) |
The three-section structure travels well everywhere. What changes is the surrounding layer: payer time-and-signature rules in the US, college record and access standards in Canada, and program-cycle reporting in Australia.
BastionGPT is specifically trained, tuned, and clinically tested on DAP notes.
See how clinicians use it day to day on the AI therapy notes page.
Many BastionGPT users report saving more than 90 minutes per day on documentation.
HIPAA-compliant with a signed BAA on every plan. Your data is never used to train models. BastionGPT drafts, you review and sign.
DAP combines SOAP's Subjective and Objective sections into a single Data section, then keeps Assessment and Plan. DAP suits qualitative psychotherapy documentation and solo or behavioral-health settings; SOAP reads better in integrated and multidisciplinary settings where the subjective/objective split aids communication. Neither is legally required; the choice is workflow, not compliance.
Everything the session produced: the client's report, your observations and mental-status highlights, measurable scores or logs, the interventions you delivered, and therapy time when a time-based code is billed. Include at least one observable or measurable anchor; pure narrative is the section's most common weakness.
A DAP variant that adds a Response section: Data, Assessment, Response, Plan. Teams use it when they want the client's reaction to interventions recorded separately instead of folded into Data or Assessment. If response-tracking matters operationally, BIRP is the other common choice.
Usually not. HIPAA's psychotherapy-notes category excludes diagnosis, treatment plan, symptoms, prognosis, progress, and session timing, exactly what a working DAP note contains. A DAP note used for care and billing is part of the standard record; true psychotherapy notes must be kept separately and have their own authorization rules.
Yes. No payer in the sources we reviewed mandates a note format by name. What reviewers require is content: documentation that supports the billed service and time, links the session to an individualized treatment plan, and is signed and dated. A DAP note that carries those elements is as payer-ready as a SOAP note.
The official guidance is mixed: Medicare's current billing article accepts start/stop times or total time for time-based psychotherapy codes, while an older contractor fact sheet says exact times must be documented. Because both float around audit desks, recording start and stop times remains the most defensible practice.
Most run 150 to 300 words and take 10 to 20 minutes by hand (our clinical team's estimate; no published benchmark exists, and vendor time-saving statistics for DAP are marketing claims rather than research). Long enough to carry a measurable anchor, named interventions, an interpretation, and a dated plan.
Not automatically. Ontario's psychotherapy college, for example, releases a joint record in full only when all participants consent or request together; a single requester gets their own information plus communal content not attributable to another participant. Wherever you practice, write joint-therapy notes so each person's content can be severed cleanly.
Yes. Paste a transcript, dictate, or give it bullets, and it produces a structured DAP draft for your review. It can also convert notes between DAP, SOAP, BIRP, and narrative structures. BastionGPT is HIPAA-compliant with a signed BAA on every plan, and your data is never used to train models.
The compliance claims on this page trace to these authorities, last verified July 2026:
Educational content, not legal or billing advice. Sample notes are fictional. Follow your organization's policies and your board, payer, and jurisdiction requirements.