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March 15, 20253 min read
Medicare Behavioral Health Documentation Checklist
A comprehensive checklist for Medicare behavioral health documentation covering medical necessity, risk assessment, symptom documentation, clinical justification, and treatment interventions.
By Susanna Vogel, Content Marketing Director, Brellium
Medicare Behavioral Health Documentation – Practical Note Template
Use the prompts below in each note to clearly show why this visit was medically necessary right now and to support Medicare requirements.
1. Medical Necessity – Why THIS Visit, RIGHT NOW
- Current clinical presentation & acute needs:
- Presenting symptoms today (onset, duration, severity):
- e.g., "Reports 6 days of worsening insomnia (sleeping ~3 hours/night), increased tearfulness, and difficulty concentrating at work."
- Acute stressors/changes since last visit:
- e.g., "Recent job warning, conflict with spouse, anniversary of loss."
- Why symptoms require intervention now:
- What would likely happen without this visit?
- e.g., "Without intervention, patient at risk for job loss and worsening depressive symptoms."
- Functional impairment linked to symptoms:
- Work/school: "Missed _ days; productivity reduced by ~_%."
- Home/ADLs: "Difficulty completing chores, bathing, cooking, managing meds/finances."
- Social: "Avoiding friends/family, canceled ___ events."
- Health: "Poor adherence to medical care, missed ___ appointments."
- Justification of timing, frequency, and level of care:
- Why this visit today (vs. later)?
- Why this frequency (e.g., weekly vs. monthly)?
- Why this level of care (outpatient vs. IOP/PHP/inpatient)?
2. Risk Assessment & Safety Evaluation
- Suicide risk:
- Ideation: present/absent; passive vs. active; frequency; intensity.
- Plan: present/absent; specificity; access to means.
- Intent: present/absent.
- History: past attempts, self-harm, hospitalizations.
- Protective factors: supports, reasons for living, engagement in care.
- Harm to others / violence risk:
- Thoughts, plans, intent, access to weapons, history of violence.
- Non-suicidal self-injury / self-harm:
- Methods, frequency, severity, medical risk.
- Current safety status:
- e.g., "Denies current SI/HI; no plan or intent; contracts for safety; agrees to seek help if symptoms worsen."
- Changes from previous visit:
- e.g., "SI decreased from daily passive thoughts to rare fleeting thoughts; no plan or intent today."
- Safety planning (when applicable):
- Safety plan reviewed/updated; warning signs; coping strategies; supports; emergency contacts; crisis resources; means restriction.
3. Specific Symptom Documentation
- Standardized measures (when used):
- PHQ-9: score ___ (previous ___); notable item scores.
- GAD-7: score ___ (previous ___).
- Other scales (e.g., PCL-5, MDQ, AUDIT-C): score and comparison.
- Depressive symptoms (examples):
- Low mood, anhedonia, sleep, appetite, energy, concentration, guilt, psychomotor changes, hopelessness.
- Frequency/duration: "5/7 days," "most of the day," ">2 weeks."
- Anxiety symptoms (examples):
- Excessive worry, restlessness, muscle tension, irritability, panic attacks (frequency, duration, triggers), avoidance behaviors.
- Other relevant symptoms:
- Psychosis: hallucinations, delusions, disorganization (with examples).
- Mania/hypomania: decreased need for sleep, pressured speech, grandiosity, risky behavior.
- Trauma-related: re-experiencing, avoidance, hyperarousal, negative cognitions.
- Substance use: type, amount, frequency, last use, consequences.
- Functional impact (measurable):
- e.g., "Missed 3 of 5 workdays last week due to panic attacks,"
"Spent ~6 hours/day in bed,"
"Late paying 2 bills due to poor concentration."
- Changes from baseline/previous visit:
- "Sleep improved from 3 to 6 hours/night."
- "Panic attacks decreased from daily to 2x/week."
- "No change in anhedonia despite 4 weeks of treatment."
4. Clinical Justification (Level & Frequency of Care)
- Why this level of care is appropriate:
- Why outpatient is sufficient (or why higher level not needed):
- e.g., "No imminent risk, stable housing, able to adhere to outpatient plan; does not require 24-hour monitoring."
- If higher level considered and not chosen, document rationale.
- Why this frequency of visits is necessary:
- e.g., "Weekly visits needed to monitor recent medication change and manage escalating anxiety impacting work attendance."
- If reducing frequency, explain why (stability, progress, patient preference).
- Link treatment plan to specific symptoms and goals:
- Symptom → Goal → Intervention.
- e.g., "Panic attacks (4x/week) → goal: reduce to ≤1x/week in 8 weeks → CBT for panic + exposure + breathing techniques."
- Progress toward goals OR justification for continued care:
- Progress: "PHQ-9 decreased from 18 to 10; now attending work full-time."
- If limited/no progress:
- Identify barriers (e.g., nonadherence, psychosocial stressors, comorbidities).
- Document treatment adjustments (med changes, new modality, referrals).
- Justify why continued treatment is still medically necessary.
5. Treatment Intervention Documentation
- Be specific about what you did (not just "discussed"):
- Psychotherapy examples:
- CBT: cognitive restructuring, behavioral activation, exposure, thought records.
- DBT: distress tolerance, emotion regulation, interpersonal effectiveness, mindfulness.
- Trauma-focused: grounding, processing trauma memories, cognitive processing.
- Supportive therapy: validation, problem-solving, strengthening coping and supports.
- Medication management examples:
- Medications started/stopped/adjusted (dose, schedule, rationale).
- Side effect assessment and management.
- Lab/ECG monitoring and rationale.
- Patient response to interventions:
- Engagement, insight, ability to use skills, homework completion.
- Immediate effect (e.g., decreased distress by end of session) when applicable.
- Adjustments based on clinical response:
- Changes to diagnosis, treatment modality, frequency, medications, referrals.
- Rationale for each change.
- Document clinical decision-making:
- e.g., "Chose to increase SSRI due to persistent moderate depressive symptoms and good tolerability at current dose."
- "Did not hospitalize because patient denies intent/plan, has strong supports, and agrees to safety plan with close follow-up."
6. Final Pre-Claim Checklist (Quick Self-Audit)
Before signing/submitting the note, confirm:
- Medical necessity clearly stated:
- Can a reviewer see why this visit was needed today (acute change, risk, functional impact)?
- Symptoms are quantified and specific:
- Use frequencies, durations, severity ratings, and standardized scores when available.
- Risk and safety are clearly documented:
- Current risk status, changes from prior visit, and any safety plan or higher-level care considerations.
- Level and frequency of care are justified:
- Explicit rationale for outpatient level and visit frequency.
- Interventions and responses are documented:
- Specific techniques/med changes, patient response, and clinical reasoning.
If the medical necessity is not obvious on a quick read, add:
- More specific symptoms,
- Clear functional impairment, and
- Explicit rationale for why intervention was required now.
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