Preliminary hearing, Billing for psychotherapists

This article is intended for psychotherapists and provides practical guidance on billing for probationary sessions in accordance with the EBM, GOÄ/GOP, and government assistance laws. Those who bill for probationary sessions must adhere to three sets of regulations. Health insurance providers reimburse based on the Uniform Assessment Scale (EBM); for private patients, the Fee Schedule for Physicians (GOÄ) applies; and the government subsidy program has its own caps.

Effective as of August 20, 2026.

Patients with public health insurance do not pay any copayment. However, billing is not handled directly by the health insurance provider but through the Association of Statutory Health Insurance Physicians, which distributes the fees from the total reimbursement. This makes no difference to the patient, but it changes everything for the practice. Privately insured patients receive a bill and submit it to their insurance company; the amount reimbursed is specified in their plan. Those eligible for government-subsidized health insurance have their own coverage limits, which differ from those of the public health insurance system.

The three systems use the same terms for different things, and that is the source of most of the confusion, even among colleagues. The amount a patient ultimately pays is listed on the page about Costs of the preliminary hearing. Here are the numbers behind them, the amounts, and the limits.

The health insurance provider reimburses through a single fee schedule item (GOP): 35150. It is valued at 709 points, which amounts to Reference value of 12.7404 cents 90.33 euros per 50 minutes completed. It is payable a maximum of four times in the event of illness; for child and adolescent psychotherapy and for insured persons with an intellectual disability, a maximum of six times.

On the internet, the numbers five and eight are very often cited in this context. Those figures are correct, but they apply to the subsidy. The decisive factor for health insurance is Section 12, Paragraph 3 of the Psychotherapy Guidelines: Before starting guideline-based treatment, a minimum of two sessions is required and a maximum of four is allowed; for children, adolescents, and people with intellectual disabilities, two additional sessions are required.

Two aspects of this are regularly overlooked. First, diagnostic testing does not count toward treatment quotas; it is not considered standard-of-care treatment. Second, video consultations have been permitted here as well since January 1, 2025, but not without restrictions. The Psychotherapy Agreement I would like to continue to see at least 50 minutes of consultation time and at least 50 minutes of probationary care involving direct in-person contact; purely digital care is permitted in justified exceptional cases, such as at the patient’s express request. In addition, there is a limit that applies to the entire practice: treatment cases in which an insured patient is seen exclusively via video during a quarter may account for no more than half of all treatment cases, and the basic flat fee is reduced by 20 percent in such cases.

Here's How Billing Works in the Event of Illness

It counts in the event of illness, which includes at the same doctor's office the current quarter and the three subsequent quarters. However, this does not mean four meetings in four quarters: they may be scheduled as closely together as is professionally reasonable, up to and including a double session, which KV North Rhine-Westphalia expressly confirmed. The 35150 charges for every full 50 minutes, and the EBM expressly stipulates.

It cannot be billed in conjunction with outpatient consultations, acute treatment, or guideline-based therapy services. This is a billing exclusion and does not reflect the course of treatment: the combination is prohibited during the specified time period, not the sequence of sessions over several weeks. A minimum of 50 minutes of psychotherapy consultation is required. If the sessions were not provided by the same therapist, at least two of the exploratory sessions must take place in an individual setting; the guideline focuses on the individual rather than the practice, which makes a difference in group practices and medical care centers (MVZ). And if the surcharge for in-depth exploration is also applied, at least 70 minutes of contact time is required on that day.

Three codes, three purposes. Consultations are billed under code 35151, in 25-minute increments, up to six times in cases of illness; up to ten times in the context of child and adolescent psychotherapy and for insured individuals with an intellectual disability. Acute treatment is billed under code 35152, also in 25-minute increments, up to 24 times; in these two specific cases, up to 30 times. The three services may not be billed concurrently during the same session. On the same day of treatment, a combination is possible if the sessions are clearly separate; in such cases, the times must be specified.

Their current value is unclear, and you won’t find it on any advice website. The Extended Valuation Committee lowered their rating from 472 to 451 points effective April 1, 2026, which would amount to 57.46 euros instead of 60.13 euros. On July 9, 2026, the Berlin-Brandenburg State Social Court The immediate enforcement of this decision has been suspended; case number L 7 KA 11/26 KL ER. Since then, the reduction may not be applied until a final and binding decision has been rendered; accordingly, fee notices issued starting in the second quarter of 2026 are subject to a reservation of recovery. Probationary services were not covered by the decision in the first place: the 90.33 euros of the 35,150 remain unaffected.

People often ask about a code that has nothing to do with probation: 23216. This is the surcharge for basic psychotherapeutic care added to the basic flat rates 23210 through 23212 and 23214—170 points or 21.66 euros, charged once per treatment case. You are not required to bill it, but you may bill it under one condition: in that treatment case, only services of basic specialist care may have been provided and billed. These are listed in Appendix 3 of the catalog, and the answer there surprises many: code 35150 is listed without an asterisk and therefore belongs to basic care. An initial assessment, therefore, does not incur the surcharge. Code 35152 is marked with an asterisk; acute treatment incurs the surcharge, as do services provided as part of guideline-based therapy. Chapter 23 is open to medical and psychological psychotherapists, as well as specialized psychotherapists and child and adolescent psychotherapists.

What Services Are Available Before Standard Treatment Begins

It all starts with the consultation. It determines whether a patient even needs treatment, and Section 11(5) of the Directive It allows adults six 25-minute sessions, for a total of 150 minutes; for children and adolescents, the allowance is ten sessions and 250 minutes. This is the answer to the question about initial consultations, and it is more generous than many expect. Before any additional services can be provided, at least 50 of those minutes must have been completed.

This is usually followed by a trial period, but the order is not fixed. It is not required prior to acute treatment, which can follow directly after the consultation. People often draw the reverse conclusion—that the two are mutually exclusive—but this is incorrect: Section 13(5) of the guideline requires at least two trial sessions prior to guideline-based therapy following acute treatment, and the North Rhine Association of Statutory Health Insurance Physicians (KV Nordrhein) also describes the reverse scenario, in which acute symptoms arising in the middle of the trial phase necessitate acute treatment. Incidentally, the often-cited two-week period is not specified in the guideline, but rather in the private billing recommendations.

Anyone who handles a case referred through the Appointment Service Center has, until now, received a bonus. Until now.

The surcharge is not tied to the probationary code, but to the base flat rate for the case: 23228 for medical and psychological psychotherapists, and 23229 for child and adolescent psychotherapists, each applied once per group practice case. There is no fixed point value listed in the catalog; it merely states that the Association of Panel Physicians may apply the surcharge. However, it can only apply the surcharge if the practice flags the case itself, and this involves more than just checking a box: the code is assigned the letter provided by the appointment service center in the appointment confirmation (A for an acute case, B for the first through fourth day, C for the fifth through fourteenth, D for the fifteenth through thirty-fifth), in addition to the pseudo-code on the treatment form and the referral code in the practice management system. The KV Baden-Württemberg lists the steps one by one. Anyone who instead bills code 21236, as listed on the KBV website, is using a code assigned to a different group of physicians.

Under the Statutory Health Insurance Contribution Rate Stabilization Act, which took effect on July 30, 2026, this reimbursement will be discontinued no later than January 1, 2027. The The KBV specifies the date as „no later than January 1, 2027„ and estimates the loss in fees at 1.64 billion euros per year. This figure applies to all practices combined, not just psychotherapy practices. And the word “no later than” appears exactly as written in the source: this does not establish a specific deadline. An explanation of how the code on the form came about can be found on the page for the Priority Code in PTV 11.

In private practice, there is no separate code for trial sessions. Trial psychotherapy sessions are billed under the code for the approach that will be used later: 861 for depth psychology-based psychotherapy, 863 for analytical psychotherapy, and 870 for behavioral therapy. Code 870 applies analogously to systemic therapy, neuropsychological therapy, and EMDR. This is stated in the joint Billing recommendations from the German Medical Association, the Federal Chamber of Psychotherapists (BPtK), the Private Health Insurance Association, and government-sponsored health insurance providers, which have been in effect since July 1, 2024; the accompanying Q&A section is current as of October 1, 2025.

For these services, the Point value: 5.82873 cents, with the standard rate set at 2.3 times the base amount. This results in the following amounts:

The most frequently asked question is who is allowed to apply fee 849. It can be found in Section G of the fee schedule, and the Fee Schedule for Psychological Psychotherapists and Child and Adolescent Psychotherapists specifically covers sections B and G. A psychological psychotherapist is therefore permitted to bill for them, as are medical colleagues in any case. The distinction is based on content: formally, the code covers only psychoreactive, psychosomatic, and neurotic disorders and requires a minimum of 20 minutes. For brief consultations, the billing recommendations therefore apply the 804 code analogously.

Two practical details, because they affect the cost in billing. The collection lists code 849 at 30.38 euros; upon recalculation, the 2.3-fold rate based on 230 points comes to 30.83 euros, and cross-checking with code 804 matches its own figure down to the cent. So, it’s a transposed number in the document—not a problem with the fee schedule. And „GOP“ stands for “fee schedule item” in the Uniform Assessment Scale, whereas in private billing it refers to the fee schedule for psychological psychotherapists and child and adolescent psychotherapists. Same three letters, two sets of regulations.

Federal funding explicitly requires the use of probation services. Section 18, paragraph 4, of the Federal State Aid Regulation It recognizes up to five sessions; if followed by analytical psychotherapy, up to eight. For individuals under 21 years of age and for people with an intellectual disability, two additional sessions are added, bringing the total to seven and ten, respectively. Here, too, these sessions do not count toward the quotas for short-term or long-term therapy.

That is the federal rule. For state employees, the allowance regulations of their respective state apply, and a private collective bargaining agreement may also include the same limits; in that case, they would be specified in the contract rather than in the law. The only thing that can be said with certainty is this: the “five” and the “eight” do not come from the health insurance plan’s list of covered services, yet they appear on many advice websites precisely there.

In private health insurance (PKV), the amount depends on the plan. That sounds harmless, but in practice it means that two patients with the same diagnosis receive different reimbursement amounts. Two issues must be clearly distinguished here: what a practice is allowed to bill for, and what a plan actually covers. One is governed by the fee schedule, the other by the insurance terms and conditions, and a correct invoice does not constitute a guarantee of coverage. Practices should advise privately insured patients to clarify the scope of reimbursement with their insurance company in advance. In my experience, the reimbursement rate is less fixed than it sounds; in severe cases, a higher rate may also be covered.

The Billing Recommendations take a narrower view. They refer to the rates as „robust standard rates“ that may be increased only in exceptional cases, and they expressly rule out mental and physical comorbidity and chronic conditions as grounds for doing so. Anyone who goes beyond the standard benefit amount therefore needs a different reason and must specify it. Both rules coexist, and you should be aware of both before you submit a bill or receive one.

Trial sessions may also be held for self-paying patients. Although the Psychotherapy Guidelines govern care covered by statutory health insurance, billing for self-paying patients continues to be based on the GOÄ/GOP, typically under codes 861, 863, 870, or 870 by analogy.

Before the first consultation, the fee should be clearly established. There is a common misconception that persists: that without insurance, no fee schedule applies and the fee is set at the provider’s discretion. That is not true. Section 1 of the Schedule of Fees for Physicians is based on professional performance rather than on the payer, and Section 1 of the Fee Schedule for Psychological Psychotherapists and Child and Adolescent Psychotherapists points exactly to that. Anyone who is licensed bills private patients accordingly and issues an invoice.

The only option is to enter into a fee agreement, and that requires a specific form. According to Section 2 of the Schedule of Fees for Physicians It must be concluded prior to treatment, discussed in person on a case-by-case basis, and documented in writing, including the number, description, rate of increase, and amount, along with a note that reimbursement may not be full. The form must not contain any additional explanations, and the patient receives a copy. It is not valid if hidden within the general treatment agreement.

In a group setting, codes 35163 through 35169 are billed, tiered according to the number of participants (three to nine) and calculated per participant per 100 minutes: ranging from 89.69 euros for three participants to 52.11 euros for nine. If the session lasts at least 50 but fewer than 100 minutes, the Association of Statutory Health Insurance Physicians deducts 50 percent. At least one appointment must take place in an individual setting; if there has been no prior consultation with the same person, two are required. In systemic therapy, these services are also billable in a group setting. Group sessions via video are also permitted, but only with up to eight participants: code 35169 for nine participants is not included in the catalog’s video list.

If outpatient treatment follows a hospital stay, then pursuant to Section 12(6) of the Directive The necessary appointments take place during the hospital stay, either at the doctor's office or on the hospital premises.

The preliminary consultation may also be waived, but under more specific conditions than are usually stated. Section 11, Paragraph 7 lists three cases: a change of therapist after the consultation, a change during ongoing therapy, and discharge from inpatient or rehabilitative treatment with a corresponding diagnosis. A change before an initial consultation has even taken place is not included. And for discharge, the guideline does not specify a time limit, whereas the North Rhine Association of Statutory Health Insurance Physicians (KV Nordrhein) refers to a period of twelve months. Those who bill must adhere to the guidelines of their own association of statutory health insurance physicians and, in case of doubt, inquire in advance.

That leaves the question of seeing multiple practices at the same time. The guideline does not prohibit this, and the cap is set in a way that many overlook: the count is based on the occurrence of illness, which is tied to the treatment case—defined by the Federal Framework Agreement as treatment provided by the same medical practice. A patient who seeks care at two practices therefore does not use up a shared quota. This is billing information, not a free pass: concurrent treatments must be medically necessary, and two treatment plans running side by side rarely amount to one.