Guide · Record requests

Responding to a payer record request: what to check before you send

Last reviewed · 7 min read

A payer record request asks you to send documentation for specific dates of service so the payer can check that what was billed is supported by the record. The work is mostly organizational: read the request, gather the right documents for each date, check them for completeness, and send exactly what was asked for, on time.

  • ScopeThe dates and services named in the request
  • DeadlineStated in the request; diarize it
  • NeverAlter or backdate records
  • Psychotherapy notesMedicare reviewers may not request them

Step 1: Read the request closely

  • Who is asking: Medicare contractor, Medicaid program, commercial plan or a vendor acting for one.
  • Which client or clients, which dates of service, which codes.
  • What documents are listed, and how to submit them: portal, fax, mail.
  • The deadline. Put it in your calendar with a reminder a week earlier.

If anything is unclear, ask the requester in writing and keep the reply.

Step 2: Gather documents per date of service

DocumentWhy it matters
Progress note for each dateShows the service, time, content and signature
Treatment plan in force on each dateLinks the session to goals and frequency
Intake or diagnostic evaluationSupports the diagnosis codes on the claim
Plan updates and reviewsShow the plan was current during the period
Consents the payer listsFor example, telehealth consent where required

Step 3: Check completeness and consistency

  1. Every requested date has a note.
  2. Each note shows start and stop times or total time that support the code billed.
  3. Date, code and units on the note match the claim.
  4. A treatment plan was in force on each date and the note refers to it.
  5. Every note is signed with credentials and dated.
  6. Diagnosis codes match the evaluation, the plan and the claim.

Our progress note completeness checklist covers these points one by one.

Step 4: Do not alter the record

If you find a gap, do not rewrite or backdate the note. Medicare's Program Integrity Manual says the date and author of any amendment, correction or delayed entry "should be identifiable", and that the change "should be clearly and permanently denoted". For a missing signature, Medicare allows a signature attestation process in some situations (section 3.3.2.4).

Psychotherapy notes stay separate

Psychotherapy notes, as defined in 45 CFR 164.501, are process notes kept separately from the rest of the record. The definition excludes medication prescription and monitoring, session start and stop times, modalities and frequencies of treatment, results of clinical tests, and summaries of diagnosis, functional status, treatment plan, symptoms, prognosis and progress. The Medicare Program Integrity Manual (section 3.3.2.6) says Medicare reviewers shall not request psychotherapy notes, and that a refusal to submit them "shall not result in the automatic denial of a claim". Unverified Commercial plans may set their own rules in contracts; check yours.

Step 5: Send, and keep proof

  • Send only what was asked for, for the dates named.
  • Number the pages and include a cover sheet listing every document.
  • Keep an exact copy of what you sent and proof of the submission date.
  • Note the follow-up date in case the payer asks for more.

Frequently asked questions

How long do I have to respond?

The request states the deadline. Deadlines vary by payer and program, so diarize the date as soon as the request arrives and ask for an extension in writing if you need one.

Do I have to send psychotherapy notes?

For Medicare, the Program Integrity Manual says reviewers shall not request psychotherapy notes and that a refusal does not automatically deny the claim. For other payers, check the contract and ask what they need instead.

Can I add missing information now?

You can add a clearly dated late entry or amendment with your name, but never backdate or rewrite the original note.

Does a complete record mean the review will go well?

No one can promise an outcome. A complete, consistent record lets the reviewer see what was done; the decision stays with the payer.

Sources

  • CMS: Medicare Program Integrity Manual, Chapter 3, sections 3.3.2.4 (signatures), 3.3.2.5 (amendments, corrections and delayed entries) and 3.3.2.6 (psychotherapy notes) (PDF), read on October 12, 2026: cms.gov
  • 45 CFR 164.501, definition of psychotherapy notes, via Cornell Legal Information Institute: law.cornell.edu
  • CMS Medicare Coverage Database: Billing and Coding article A57520 (time documentation): cms.gov
  • Unverified Commercial plan and Medicaid record request procedures and deadlines vary and were not checked individually.

First published . Last reviewed . General information, not legal, billing or clinical advice. Check your payer contract, state rules and the cited sources before relying on it. Written by the PsyClinicAI team. Corrections: support@psyclinicai.com.