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A start-stop time attestation is the notation in a psychotherapy progress note that records when the session began and ended, or the total face-to-face minutes, to support time-based codes such as 90832, 90834, and 90837. Clinicians add it to every timed session; payers and auditors use it to verify the billed code. Most versions run one to two lines inside the note.
Therapists, psychologists, psychiatrists, and prescribers billing time-based psychotherapy or testing codes
Treating clinician, billing staff, payers, auditors
10 to 40 words · 1 to 2 minutes by hand (clinical team estimate)
Timed-service data element inside the progress note (compare: billing note, progress note)
Every session billed under a time-based CPT or MBS code, including same-day E/M plus psychotherapy visits
US Medicare policy accepts start and stop times or total time; in Australia meeting the stated duration is a condition of the MBS benefit
A start-stop time attestation is the line in a psychotherapy progress note that records the elapsed face-to-face time of the session, either as clock times (3:02 pm to 3:55 pm) or as total minutes (53 minutes), to substantiate the time-based code billed. It is a data element, not a standalone document: no US statute, Canadian health-records act, or Australian MBS item defines a separate time-attestation form. The timed-code framework dates to January 1, 2013, when the AMA's CPT overhaul replaced the old range-based psychotherapy codes (90806 covered a 45 to 50 minute range) with the specific-time codes 90832, 90834, and 90837 governed by the CPT time rule. Clinicians and billers also call it time in/time out, session start and stop, total time, length of session, or simply the time statement.
The clarification that matters most: the claim that both a start and a stop time are mandatory is a myth for US Medicare. The controlling guidance, CMS Billing and Coding Article A57520, states that time "may be documented with start and stop times or with total time." Start and stop clock times are the more audit-resistant convention, not a federal requirement. The attestation lives inside the psychotherapy progress note, which also carries the diagnosis, interventions, and plan; the claim itself is assembled in the billing note, and reviewers verify time against the clinical note, not the claim form.
Any clinician who bills a time-based code needs one in every session note: therapists and counselors billing 90832, 90834, or 90837, prescribers adding psychotherapy to an E/M visit, and psychologists delivering time-based testing services. The stakes rise in three situations: 90837, because the 53-minute floor makes the minutes decisive; same-day E/M plus psychotherapy, because the two clocks must be documented separately; and any provider whose billing pattern draws outlier analytics. Group and individual work follow the same rule, so a group therapy note and an individual therapy session note each carry their own time support. In Australia the duty is stronger: a Better Access item is payable only if the consultation ran the stated minimum, so the recorded duration is the eligibility test itself.
Date of service and service type. Anchor the time statement to the date and the service furnished (individual, group, telehealth, E/M plus add-on) so the minutes attach to one identifiable encounter. Pitfall: a time entry that floats free of the service description; a reviewer matching the claim line to the note needs both in the same place.
Start and stop clock times. The moment face-to-face psychotherapy began and ended, such as 3:02 pm to 3:55 pm. Under Medicare policy this format is optional, but it is the strongest evidence when minutes are questioned. Pitfall: copying the appointment slot from the schedule; the booked 50-minute block is not the clinical time, and a late start makes the two diverge.
Total face-to-face minutes. The computed duration, written out (= 53 minutes). Medicare accepts total time alone; record it even when you use clock times so the arithmetic is visible. Pitfall: a stated total that does not match the clock times; that internal contradiction is the first inconsistency an auditor checks.
The code the time supports. Under the CPT time rule, 16 to 37 documented minutes support 90832, 38 to 52 support 90834, and 53 or more support 90837; under 16 minutes, psychotherapy is not separately billable. Pitfall: rounding up through a threshold; a 52-minute session billed as 90837 is upcoding, however close the miss.
A separate statement for combined E/M visits. When a psychotherapy add-on (90833, 90836, 90838) accompanies an E/M service, document the psychotherapy time on its own, excluding every E/M minute, and select the E/M level by medical decision-making rather than time. Pitfall: one blended total for the whole visit; in the national OIG audit, 6 of the 60 time-documentation failures were combined visits where psychotherapy minutes were never isolated.
Signature, credentials, and date signed. Medicare's Program Integrity Manual expects records that are "legible, complete, dated, timed, and authenticated," and contractors expect notes signed when services are rendered. Pitfall: a signature added weeks later with no explanation; if a reviewer requests a signature attestation, it is due within 20 calendar days.
PSYCHOTHERAPY TIME ATTESTATION (lives inside the progress note)
Date of service: __________ Service: [individual / group / telehealth]
Psychotherapy face-to-face: start _______ stop _______ = _____ minutes
(face-to-face therapy time only; excludes intake paperwork, scheduling,
documentation time, and any E/M time)
Code supported: [ ] 90832 (16 to 37 min) [ ] 90834 (38 to 52 min)
[ ] 90837 (53+ min) [ ] add-on with E/M: _______
Same-day E/M? [ ] No [ ] Yes: E/M documented separately; no minute
counted twice; E/M level selected by medical decision-making
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: two time attestations as they appear inside progress notes, one standalone psychotherapy session and one same-day E/M visit with a psychotherapy add-on. All details are fictional.
Example 1: standalone psychotherapy. Client: R.L., 41 · Date of service: 08/11/2026 · Service: Individual psychotherapy, in office
Time attestation: Psychotherapy face-to-face: 3:02 pm to 3:55 pm = 53 minutes. Time reflects psychotherapy only; check-in, scheduling, and post-session documentation excluded. Code supported: 90837.
Signed: J. Alvarez, LPC, 08/11/2026.
Example 2: E/M visit with psychotherapy add-on. Client: D.K., 58 · Date of service: 08/13/2026 · Service: Medication management with psychotherapy
E/M portion: Documented in its own section; level selected by medical decision-making, not time.
Time attestation: Psychotherapy face-to-face: 10:12 am to 10:50 am = 38 minutes, exclusive of all E/M time. No minute counted toward both services. Codes supported: E/M service plus psychotherapy add-on 90836.
Signed: M. Osei, PMHNP, 08/13/2026.
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 bulletsSession times are part of the disclosable record, and federal privacy law says so directly: 45 CFR 164.501 lists "counseling session start and stop times" among the items excluded from HIPAA's protected psychotherapy notes. That cuts one way: you cannot withhold session times from a payer as process-note material, so keep them in the progress note where they belong. The attestation only earns its keep when the rest of the medical-necessity chain surrounds it: a current diagnosis (kept accurate through a diagnosis list update), interventions tied to goals, and a plan revisited on schedule in a treatment plan review. Retention follows the note that contains it: commonly 6 to 10 years in the US, with Medicare reviews reaching back 6, at least 10 years in Ontario under CRPO rules, and 7 years or until age 25 for minors in Australia.
Label the obligations by strength, because they differ sharply by jurisdiction. In the US the time requirement is payer policy, not statute: Medicare contractor guidance sets it, requirements vary by contractor (during the national OIG audit two contractors had no psychotherapy coverage policy at all), and CMS told the OIG "there was no requirement for uniformity across all jurisdictions for LCDs." In Canada the duty is professional convention: Ontario college record-keeping standards ask for the "duration or timing of services," not clock times. In Australia duration is law: a Better Access item such as 80110 is payable only if the session ran at least 50 minutes, and the MBS explanatory notes add that only clinical details recorded at the time of attendance count toward the consultation time, so contemporaneous entry is part of the requirement. Telehealth changes none of the arithmetic; a telehealth therapy note adds modality and location fields around the same time statement. And when a payer questions necessity across an episode rather than one session's minutes, that is prior authorization territory, a different document with a different clock.
Time documentation is the most measured failure in psychotherapy auditing. In the HHS Office of Inspector General's national audit of Medicare psychotherapy claims (May 2023), 128 of 216 sampled enrollee days failed Medicare requirements, and time was the largest single gap: 60 of the 216 days lacked time documentation, 54 with no time in either format and 6 where a combined E/M visit showed total encounter time but never isolated the psychotherapy minutes. The OIG extrapolated roughly $580 million in improper payments from those patterns, most of it a documentation-sufficiency finding rather than proof that services were not rendered. The BastionGPT Clinical Advisory Board sees the same errors most often in start-stop time attestation reviews:
BastionGPT is specifically trained, tuned, and clinically tested on start-stop time attestations.
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.
For US Medicare, total time is enough. CMS Billing and Coding Article A57520 states that time may be documented with start and stop times or with total time, and that wording was added as a deliberate 2021 clarification. Start and stop clock times remain the most audit-resistant format, so many practices standardize on writing both: start, stop, and the computed total on one line.
Keep two independent statements. Document the psychotherapy time separately, as start and stop times or as total minutes, excluding every E/M minute, and select the E/M level by medical decision-making rather than time. In the OIG's national audit, combined visits that showed only whole-encounter time were counted as failures because the psychotherapy portion was never isolated.
No. Only face-to-face psychotherapy time counts toward the timed code; pre-service and post-service work is built into the code's value. That is also why the appointment block in your calendar is not the billable time: the attestation should record when therapy actually began and ended, not when the room was booked.
No. Under the CPT time rule, 53 minutes is the floor for 90837; 38 to 52 minutes supports 90834, 16 to 37 supports 90832, and under 16 minutes psychotherapy is not separately billable. Rounding a near miss upward is upcoding, and threshold sessions are exactly where reviewers compare the clock arithmetic against the code.
No. HIPAA's definition at 45 CFR 164.501 expressly excludes counseling session start and stop times from protected psychotherapy notes, along with modality, frequency, diagnosis, and progress. Session times belong in the regular progress note, which payers may review.
No. It is a data element inside the progress note, usually one line in the header or footer. No US statute, Canadian records act, or Australian MBS item defines a standalone time-attestation form. The clinical note carries the time; the billing note translates it into codes and units on the claim. If the time line is all you have, you do not yet have a note.
In Canada, no statute names session times; Ontario college record-keeping standards ask for the duration or timing of services, a professional convention enforced through the colleges. In Australia the duty is statutory: a timed MBS item is payable only if the session met its minimum duration (item 80110 requires at least 50 minutes), and only clinical details recorded at the time of attendance count toward the consultation time.
Retention follows the progress note. US practices commonly keep records 6 to 10 years, and Medicare reviews reach back 6. Ontario's CRPO expects at least 10 years from the last interaction, or 10 years from the client's 18th birthday. Australian guidance is 7 years for adults, or until age 25 for minors, and Medicare there expects referrals kept for 24 months.
Yes. Give it a dictation, a transcript, or bullets and it drafts the note with the time statement in place: start, stop, computed minutes, and the code the time supports. It can also check finished notes for missing time, blended E/M minutes, or a threshold miss before you sign. 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.