90791 vs 90792: Who Can Bill Each Evaluation Code

The 90791 vs 90792 who can bill question comes down to one thing: whether the evaluation includes medical services. CPT 90791 is a psychiatric diagnostic evaluation without medical services. CPT 90792 is the same evaluation with medical services added. Our diagnostic evaluation code guide covers the full set of rules.

90791 vs 90792 who can bill: the short answer

Psychotherapists generally use 90791 because their evaluation has no medical component. Psychiatrists and other prescribers use 90792 when the evaluation includes a medical assessment, such as reviewing medications or ordering labs. Your license scope and each payer’s enrollment rules make the final call.

CMS lists both codes under psychiatric diagnostic evaluation in its Medicare mental health booklet (MLN1986542, revised March 2026, checked 10/23/26). The same booklet names the Medicare-eligible professionals, including physicians, nurse practitioners, clinical psychologists, clinical social workers, marriage and family therapists, and mental health counselors. It does not say which profession may bill which code, so confirm that per payer. A Psychiatric Nurse Practitioner (PMHNP) should check the payer’s rule before billing 90792.

When do you use each code?

In any 90791 vs 90792 who can bill decision, the deciding factor is the work done. Use 90791 when the first visit is an interview, history, and diagnosis with no medical work. Use 90792 when a prescriber also does the medical piece in that same evaluation. Do not choose by which pays more; choose by what you actually did and documented.

Situation	Usual code	Why
Therapist intake with history and diagnosis	90791	No medical services
Psychiatrist or psychiatric NP evaluation that includes a medical assessment	90792	Medical services included
Prescriber new-patient visit built around medication management	E/M instead	Some payers accept an E/M in place of the interview

One Medicare contractor, WPS, says in its billing and coding article (A57480, revised 1/1/26) that an E/M service can substitute for the initial interview when the E/M elements are met. Payers outside that contractor may differ.

How often can you bill 90791 or 90792?

For 90791 vs 90792 who can bill again later, the usual answer is once at the start of care, then again only when something real changes. Frequency limits are payer-specific, so check before you rebill an evaluation for an established patient.

Medicare

The WPS article (checked 10/23/26) treats the evaluation as a once-at-onset service. It allows a repeat after an extended break in care, which that contractor puts near six months. It also allows a repeat for an inpatient psychiatric admission or a significant change in mental status. That article covers WPS jurisdictions only, and other Medicare contractors publish their own versions. Look up your contractor’s policy. CMS also runs a Physician Fee Schedule look-up tool for payment amounts by code and locality.

Private payers and Medicaid

Private payers and state Medicaid programs set their own limits, and they vary by payer and by state. Some count by calendar year, some by provider, some by lifetime of the episode. Pull the payer’s policy for each plan you bill, and keep the answer in your billing notes.

What should you document for each code?

Your note should back up the 90791 vs 90792 who can bill choice. Document the reason for the evaluation, the history, the mental status findings, the diagnosis, and the plan. CMS tells providers to record the specific sign, symptom, or complaint behind each service billed (MLN1986542, checked 10/23/26). For 90792, add the medical work you did, so a reviewer can see why it was not a 90791.

• Chief complaint and history of present illness
• Mental status exam and diagnosis
• Medical elements for 90792, such as medication review or orders
• Treatment plan and next visit
• Start and stop time if the payer asks for it

Sloppy Progress Note habits show up in audits first, so keep the evaluation note complete.

Can you bill the evaluation and psychotherapy on the same day?

Sometimes, but payers differ and edits can bundle the claim. CMS says Medicare may pay multiple mental health services on one day, but not duplicate or inappropriate ones (MLN1986542). Check your payer’s rules and the psychotherapy add-on code rules before pairing codes. Adding Interactive Complexity (90785) has its own requirements. If you are choosing between an evaluation and a regular session, read 90791 or 90834. Our 90791 vs 90792 overview and the CPT 90791 billing guide go deeper on each code. The documentation requirements guide and the full CPT and E/M code guide help too.

How MCM South helps

MCM South Medical Billing Service, LLC works only with mental and behavioral health practices, including solo and medium-size practices of psychotherapists and psychiatrists. We check the code, the documentation, and the payer’s rules before a claim goes out. Learn more on our billing services page.

90791 vs 90792 who can bill: the quick recap

In short, 90791 vs 90792 who can bill comes down to medical services and payer rules. Write the answer to 90791 vs 90792 who can bill into your billing policy, per payer, so every new hire gets the same answer.

Related reading: a psychiatric billing service checklist and psychological testing billing codes.

Frequently asked questions

Where MCM South works

MCM South works only in mental and behavioral health. We serve psychotherapists and psychiatrists in solo and medium-size practices across ten currently served states: Georgia, Massachusetts, Connecticut, Texas, Florida, New York, Colorado, Tennessee, North Carolina and Illinois. Need a payer contact? Use our insurance companies contact directory.