Guide · Treatment plans

Treatment plan updates every 90 days: what to review and how to document it

Last reviewed October 12, 2026 · 7 min read

A treatment plan update (plan review) records where the client stands against each goal and what happens next. No single federal rule sets the interval for every payer. A Medicare contractor policy for outpatient psychotherapy, for example, expects the plan to be updated "generally at least every three months", and many commercial plans and state Medicaid programs set their own interval. Your payer contract and state rules decide.

• IntervalSet by payer or state; 90 days is common
• Written byThe treating clinician, with the client
• Core contentGoals, measurable objectives, progress, next review
• Sign-offSigned and dated by you

Where the 90 days comes from

Medicare local coverage determination L33252 (Psychiatric Diagnostic Evaluation and Psychotherapy Services, First Coast Service Options) says the individualized treatment plan must include "methods of therapy, anticipated length of treatment to the extent possible, and a description of the planned measurable and objective goals". It asks for documentation to be updated "on a periodic basis, generally at least every three months".

That policy binds Medicare claims in that contractor's jurisdictions. Unverified Commercial plans, Medicaid managed care organizations and state licensing rules use a range of intervals, and some only ask for a current plan when they review records. Look in your provider manual or contract for the exact wording, and use the stricter interval if two apply.

A ten-part structure for the update

1. Identification and dates. Client, plan start date, review date, period covered.
2. Diagnoses. Current ICD-10-CM codes as you documented them, with any change since the last plan.
3. Presenting concerns. Brief restatement of the problems the plan addresses.
4. Goals and measurable objectives. One or more objectives for each goal.
5. Progress per objective. Evidence from dated notes and repeated measures.
6. Interventions. What you used during the period and what will change.
7. Barriers. Missed sessions, life events, anything slowing progress.
8. Frequency and duration. Session frequency, modality and expected length of treatment.
9. Next review date. A specific date, not "in three months".
10. Signatures. Your signature, credentials and date; the client's signature if your payer or state asks for it.

Make objectives measurable

The same LCD warns that generic statements such as "supportive psychotherapy given" are not enough; notes should show "what the psychotherapy entailed and how it is addressing the presenting problem". A plan with measurable objectives makes that link easier to show in every note.

Gaps worth checking

• The review date has passed and services continued without an update.
• Goals are copied unchanged from plan to plan for a year or more.
• A measure was used at intake and never repeated.
• The plan was signed after the services it covers were billed.
• The frequency in the plan does not match the sessions actually held.

If you notice a missed update, write it now and date it honestly. Medicare's Program Integrity Manual expects the date and author of any amendment, correction or delayed entry to be identifiable. Never backdate.

Progress notes carry the plan between reviews. Our progress note completeness checklist covers dates, times and CPT duration.