How do I appeal a CARC 150 denial?

Primary argument: Code selection for timed psychotherapy codes is controlled by the CPT time rule — 53 or more minutes of face-to-face psychotherapy is correctly reported as 90837 — and the contemporaneous record documents the required session time, so the information submitted does support the billed level of service. 90837 is a standard, time-defined CPT code; nothing in CPT or APA coding guidance requires exceptional circumstances beyond documented session length. Supporting points: APA coding guidance confirms that sessions of 53 or more minutes — including sessions that run past 60 minutes — are reported with 90837; a clinician whose patients clinically need hour-long sessions is coding correctly, not overcoding. Subjecting 60-minute psychotherapy to heightened documentation standards or systematic downcoding that is not applied comparably to time-based medical/surgical services operates as a nonquantitative treatment limitation; under MHPAEA, the processes, strategies, and evidentiary standards applied to MH/SUD benefits must be comparable to and applied no more stringently than those for medical/surgical benefits. MHPAEA also imposes disclosure requirements on plans — request the specific written policy, criteria, and evidentiary standards the reviewer applied, and identification of exactly which information was found insufficient. The clinical record documents why extended sessions are indicated for this patient (e.g., trauma-focused protocols, symptom severity, complexity), further supporting the appropriateness of the billed level of service.

What public sources support a CARC 150 appeal?

X12 — Claim Adjustment Reason Codes (official): Official wording of CARC 150 (start 10/31/2002, last modified 09/30/2007) (https://x12.org/codes/claim-adjustment-reason-codes) | APA Services — Psychotherapy codes for psychologists: CPT time rule: 90832 = 16–37 min, 90834 = 38–52 min, 90837 = 53+ min; code selection is based on actual session duration (https://www.apaservices.org/practice/reimbursement/health-codes/psychotherapy) | APA Services — Psychotherapy Services FAQ: Sessions exceeding 60 minutes are still reported with 90837; only face-to-face psychotherapy time counts toward code selection (https://www.apaservices.org/practice/reimbursement/health-codes/psychotherapy-services-faq) | CMS — The Mental Health Parity and Addiction Equity Act (MHPAEA): NQTLs (including medical management) must be comparable to and applied no more stringently than for med/surg benefits; MHPAEA imposes disclosure requirements on plans (https://www.cms.gov/marketplace/private-health-insurance/mental-health-parity-addiction-equity) | APA Services — Legal Corner: Highmark letters to psychologists: Documented payer campaigns (Highmark/Anthem via Change Healthcare) targeting psychologists identified as high utilizers of 90837 (https://www.apaservices.org/practice/update/2017/11-09/highmark-letters)

CARC Code

CARC 150 Denial Appeal

Level of service not supported by documentation

Payer deems the information submitted does not support this level of service.

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Why CARC 150 hits behavioral-health claims

CPT 90837 (psychotherapy, 60 minutes) reimburses meaningfully more than 90834 (45 minutes), so payers profile therapists' code mix and flag anyone billing 90837 above peer averages — Highmark and Anthem mailed letters to psychologists identified as 'high utilizers' of 90837, and several plans deny or downcode 90837 to 90834 under CARC 150 as if a routine 60-minute session required special justification. Because the two codes differ only by documented face-to-face time (53+ minutes vs. 38–52), a progress note missing start/stop or total session time gives the payer an easy hook, and telehealth sessions draw the same scrutiny.

The winning argument

Code selection for timed psychotherapy codes is controlled by the CPT time rule — 53 or more minutes of face-to-face psychotherapy is correctly reported as 90837 — and the contemporaneous record documents the required session time, so the information submitted does support the billed level of service. 90837 is a standard, time-defined CPT code; nothing in CPT or APA coding guidance requires exceptional circumstances beyond documented session length.

APA coding guidance confirms that sessions of 53 or more minutes — including sessions that run past 60 minutes — are reported with 90837; a clinician whose patients clinically need hour-long sessions is coding correctly, not overcoding.
Subjecting 60-minute psychotherapy to heightened documentation standards or systematic downcoding that is not applied comparably to time-based medical/surgical services operates as a nonquantitative treatment limitation; under MHPAEA, the processes, strategies, and evidentiary standards applied to MH/SUD benefits must be comparable to and applied no more stringently than those for medical/surgical benefits.
MHPAEA also imposes disclosure requirements on plans — request the specific written policy, criteria, and evidentiary standards the reviewer applied, and identification of exactly which information was found insufficient.
The clinical record documents why extended sessions are indicated for this patient (e.g., trauma-focused protocols, symptom severity, complexity), further supporting the appropriateness of the billed level of service.

Public sources you can cite

Every argument traces to a verified public source — no invented citations.

Sample appeal letter body

Replace the {{placeholders}} with your own information before sending.

We are appealing the denial (or downcoding) of CPT 90837 for {{patient_reference}}, date of service {{date_of_service}}, adjusted under CARC 150 (information submitted does not support this level of service). Under the CPT time rule, psychotherapy of 53 or more minutes is correctly reported with 90837, and the contemporaneous progress note documents {{documented_session_minutes}} minutes of face-to-face psychotherapy ({{session_start_stop_times}}), which supports the billed code on its face. The extended session was clinically indicated because {{clinical_rationale_for_60_minutes}}. CPT 90837 is a standard, time-defined code; it does not require exceptional circumstances beyond documented session time. To the extent the plan applies heightened documentation or review standards to 60-minute psychotherapy that are not applied comparably to time-based medical/surgical services, that practice operates as a nonquantitative treatment limitation subject to the comparability and stringency requirements of the Mental Health Parity and Addiction Equity Act. We request that the plan identify the specific information found insufficient, provide the written policy or criteria applied to this determination, and reprocess the claim at the billed level of service.

You'll need to supply: patient_reference (member ID / claim # — fill locally), date_of_service (date of the denied session), documented_session_minutes (total face-to-face minutes from the note, e.g., 58), session_start_stop_times (start/stop times as documented, e.g., 3:00–3:58 pm), clinical_rationale_for_60_minutes (e.g., trauma-processing protocol such as EMDR/PE, symptom acuity, clinical complexity)

What this argument cannot ground

Honest gaps — no fabricated sources.

CARC 150 is a generic level-of-service code that also appears on E/M and ER-leveling denials; this entry targets the psychotherapy 90837-vs-90834 subcase specifically.
If the progress note does not actually document 53+ minutes (no start/stop or total time), the downcode is likely correct — corrected billing or improved documentation going forward beats an appeal. Only appeal when documented time supports 90837.
When paired with group code CO, payers process this as a contractual adjustment; reconsideration/appeal rights for documentation-based determinations still generally exist, but check the remittance advice and your participation agreement.
The MHPAEA/NQTL framing does not apply to all coverage (e.g., traditional Medicare); confirm the plan type before leaning on the parity argument.
The Highmark/Anthem 90837 letters were officially framed as 'educational,' so avoid asserting that any payer has a formal policy requiring extra justification for 90837 — frame it as how the review operated in practice.

Argument confidence85%

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