Regarding Insurance & Couples Therapy

Please note that as of January 2026, I no longer offer family/conjoint therapy (90847), and cannot accept insurance payment for "couples therapy".  To bill for insurance CPT code 90847, it is required that the therapist deem the care “medically necessary”, and assign one partner as the “identified patient” and give them a mental health diagnosis to be addressed via a treatment plan. For insurance purposes, the treatment plan is a legal document that the therapist is accountable for following. Although the modalities I use in couples therapy (RLT, PACT, Gottman) are evidence-based, they are not medical treatment for mental health disorders for individuals. They are educational and skills-based approaches to addressing relationship disharmony, disconnection, miscommunication, unhelpful behavioral habits and relational wounds. My insurance documentation platform, Headway, does not allow me to include these modalities in my case notes. If I were to write a treatment plan and accompanying progress notes that did not reflect the truth of the work we do together in relationship therapy, I would be committing insurance fraud, exposing my business and therapist license to undue risk, and violating my insurance contracts resulting in their termination and immediate disruption of care for my individual insurance-pay clients. 

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Additionally, by practicing conjoint therapy, the clinical notes and PHI for my relationship clients will only belong to the identified patient in each couple. This has recently become problematic and relevant to my practice, as I am now being asked to participate in court cases for past relationship therapy clients. My required involvement in lawsuits like these makes it especially necessary that I take precaution in conducting ethical and accurate insurance practices. 

 

In order to protect my individual clients' ability to use their insurance for medically necessary care, as well as to protect partners who are not the identified patient in conjoint therapy, and to protect my practice from liability for fraudulent billing of 90847, I will no longer be offering family/conjoint therapy or inaccurately billing my relationship therapy as such. 

 

Q: But other therapists accept insurance for couples’ therapy, why don’t you? Other therapists might conduct couples therapy that addresses the mental health diagnosis of one partner using insurance-approved modalities for that purpose. Or, other therapists may have more comfort with the level of risk involved in inaccurately representing their work in insurance documentation.

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Q: Aren't you required to use my insurance for couples’ therapy if you’re in-network with my provider? It is not allowed for therapists to refuse to accept insurance payment for services they offer that are covered by insurance. However, I no longer offer family/conjoint therapy. No health insurance provider covers educational, skills-based, non-medically necessary relationship therapy. Family or conjoint therapy requires one person to be the identified patient with the focus of treatment being to alleviate the patient's mental health diagnosis while their partner or family is in session in support of the patient's medical treatment. I do not currently offer this kind of therapy.

 

Regarding Court Appearances & Participation in Court Cases

As my client in relationship/couples therapy is the relationship, not one individual or the other, I do not respond to requests to testify in court on behalf of one party of a relationship. Acknowledging to a lawyer or process server my association with any party whom I have seen in therapy would result in a HIPAA violation. In the event that all client parties consent in writing to my disclosure of our therapeutic relationship and the PHI of our sessions together, I am able to appear in court. The other condition in which I must appear in court, even without client consent of PHI disclosure, is if I receive a qualified order from the court (a “court-ordered” subpoena, signed by a judge). In the event of receiving such an order, I will inform all client parties that I will be disclosing their PHI as mandated by a court of law; therefore not violating HIPAA.

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In the State of Texas, mental health therapists may charge for records retrieval, administrative preparation, recoupment of cancelled clinical hours, and their testimony appearance in court even if subpoenaed. It is the party that requested the therapist’s presence who is responsible for this fee. I charge based on my typical hourly rate: $216 per hour, for an 8 hour-day minimum ($1728) that must be paid before I will begin work in service of your court case. As a reminder, in couples therapy, the relationship is the client not either individual. My testimony and case notes will reflect that accordingly.