Industry Reports

State of Behavioral Health Practice 2026: Demand, Pay and Rules

State of behavioral health practice 2026: need, workforce gaps, how practices get paid, telehealth, records, AI rules, income and software costs.

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In 2024, about 14 in 100 U.S. adults saw a therapist or counselor. By September 2026, the federal government listed 7,127 places, groups and facilities as short of mental health professionals. This state of behavioral health practice 2026 report is for therapists, counselors, psychologists, prescribers and owners of group practices and outpatient addiction programs. You will learn how big the need is, how practices get paid, which privacy, telehealth and artificial intelligence (AI) rules apply, and what software costs. It focuses on the United States, and every figure carries its data year.

Quick Answer

The state of behavioral health practice in 2026 is high need, short supply and rules that change on set dates. In 2022, about half of adults with a mental illness got treatment (National Institute of Mental Health, 2022). In 2025, 46% of surveyed psychologists had no openings for new patients (American Psychological Association, 2025).

Payment and telehealth rules change between December 2026 and January 2028. Psychotherapy notes (a therapist's private notes on a session, kept apart from the chart) and substance use records get extra privacy protection. In at least six states whose laws limit AI therapy (Illinois, Nevada, Maine, Colorado, Vermont and Rhode Island), AI may help with administrative work under conditions.

Software here means electronic health record (EHR) software, which holds client charts and notes. A median is the middle price: half of vendors charge more and half charge less. For a solo therapist, the median software price is $86 a month across 7 vendors with published prices in our calculator, without ClinikEHR. With ClinikEHR, it is $87 across 8 (EHR cost calculator, 2026).

Key numbers

  • 14.0% of U.S. adults saw a mental health professional for counseling or therapy in 2024, and 19.3% took medication (Centers for Disease Control and Prevention, 2024).
  • 7,127 mental health shortage designations (places, groups and facilities) cover about 154.6 million people (Health Resources and Services Administration (HRSA), September 30, 2026). HRSA projects 2038 shortfalls of about 99,840 psychologists and 99,780 mental health counselors (HRSA, 2038 projection).
  • 38% of psychologists accept no health insurance, 46% have no openings for new patients, and 34% say they feel burned out (American Psychological Association, 2025).
  • Medicare pays for mental health telehealth at a patient's home, without the in-person visit rule, through December 31, 2027. After that, a patient needs an in-person visit within 6 months before the first service; patients already receiving it at home by then need an in-person visit at least every 12 months instead (Centers for Medicare & Medicaid Services (CMS), 2026). Prescribing controlled medications by telemedicine is allowed through December 31, 2026 (Drug Enforcement Administration, 2025 rule).
  • Three federal departments plan to send a proposed replacement for the parity rule to White House review by December 18, 2026. Parity means equal limits on mental health and medical benefits (court filing, September 30, 2026).
  • At least 6 states (Illinois, Nevada, Maine, Colorado, Vermont and Rhode Island) limit AI therapy but allow administrative uses under conditions. We read the laws or official summaries for the first four, which date from 2025 and 2026; Vermont's Act 156 (signed June 17, 2026) and Rhode Island's H 7349 (signed June 22, 2026) came later (Illinois, Nevada, Maine, Colorado). In a 2026 survey, 54.6% of 766 clinicians in 30 countries had used a generative AI tool in practice at least once. Generative AI is AI that writes text, such as ChatGPT (JMIR Mental Health, 2026).
  • About $29,800 is the mean net income per sole-proprietor mental health tax return in 2023, roughly half of receipts. A sole proprietor owns a business alone, with no separate company (Internal Revenue Service, tax year 2023).
  • $86 a month is the median software price for a solo therapist across 7 vendors with published prices in our calculator, without ClinikEHR. With ClinikEHR it is $87 across 8 (read September 26, 2026) (EHR cost calculator, 2026).

At a glance

Need is high, appointments are scarce, and the average sole proprietor nets about $29,800

Six numbers from this report, each with its data year. The average sole proprietor nets little, part-time practices included.

  • 14.0%

    Adults who saw a therapist or counselor

    In the past 12 months, in 2024

  • 7,127

    Mental health shortage designations

    Places, groups and facilities covering about 154.6 million people (as of September 30, 2026)

  • 38%

    Psychologists who accept no insurance

    Survey of licensed psychologists, 2025

  • 34%

    Psychologists who feel burned out

    51% of those within 10 years of their doctorate (2025)

  • $29,800

    Mean net income, sole proprietors

    About half of receipts, tax year 2023, part-time practices included

  • $86

    Median software price a month, solo

    7 vendors with published prices in our calculator, without ClinikEHR; $87 across 8 with it (September 2026)

Each figure carries its own data year in the detail line. Prices are published list prices read on September 26, 2026.

2023 to 2026Sources: CDC National Center for Health Statistics · HRSA shortage area report · American Psychological Association 2025 Practitioner Pulse Survey · IRS sole proprietorship table · ClinikEHR EHR cost calculator

How We Gathered This Data

We read federal data briefs and rules, court filings, state laws, peer-reviewed studies, surveys from professional groups and each company's own pages. We read everything in September and October 2026, and every number carries its data year. We left out pages we could not open, secondhand figures where an original existed, and figures whose definitions conflict. SAMHSA, the federal Substance Abuse and Mental Health Services Administration, blocked our tools on its own pages. So the need figures use its 2024 report, read in a copy hosted by the UNC School of Medicine.

Our EHR cost calculator holds 123 products: 114 full EHRs and 9 one-job tools. An EHR, or electronic health record, is the software that holds client charts and notes. Seven of the 114 are free projects a practice installs itself, so we leave them out of price statistics, which leaves 107 full EHRs. We read each price on the vendor's own pricing page on September 26, 2026. "Published" means the page gives a price for at least some practice sizes.

We build ClinikEHR, and it is one of the 107. Where it changes an answer, we show results with and without it. Its figures include features our team confirmed that its pricing page does not list.

We count one note and one reminder per session, and one claim per billed session. Where a vendor's file prices them per client, we count per client. So 110 sessions with 70% billed to insurance give 77 claims (110 times 0.70).

"Monthly" is the steady price after first-year discounts, before card fees. "First year" adds set-up fees and uses first-year rates. SimplePractice claim rates are those effective October 1, 2026.

We quote a median only when 5 or more vendors remain without ClinikEHR. A vendor sits in a "nothing missing" group only when nothing on its pricing page is missing, unpriced or unlisted for the features we picked. A vendor left out may have the feature.

Insurance networks such as Headway, Alma, Rula, Grow Therapy and SonderMind are not software, so we keep them out of every median. We read their facts on each network's own pages and checked them on September 29, 2026. We re-read some of the Alma, Grow Therapy and Rula pages on October 6, 2026. This state of behavioral health practice 2026 report covers the United States, because that is where the public data we could read come from.

How big is the need for behavioral health care, and how many people get it?

The need is large. In 2022, about half of adults with any mental illness got treatment, and those 2022 data are not comparable with 2024. The table gathers the figures, and four steps explain how to read them.

MeasureFigureData year and source
Any mental illness, adults23.4% (61.5 million)2024, SAMHSA
Serious mental illness, adults5.6% (14.6 million)2024, SAMHSA
Substance use disorder, ages 12 and older16.8% (48.4 million), between 48.4 and 48.7 million each year since 20222024, SAMHSA
Mental health treatment, all adults22.9% (60.1 million)2024, SAMHSA
Substance use treatment, all adults3.6% (9.4 million)2024, SAMHSA
Saw a mental health professional for counseling or therapy14.0% (women 16.9%, men 10.9%; ages 18 to 29 20.2%, ages 75 and older 5.0%)2024, CDC
Took medication for mental health19.3%2024, CDC
Got treatment, adults with any mental illness50.6% (30.0 million of 59.3 million)2022, National Institute of Mental Health
Got treatment, adults with serious mental illness66.7% (10.2 million of 15.4 million)2022, National Institute of Mental Health
Drug overdose deaths69,973 estimated in 2025, against 81,313 in 20242025, provisional, CDC
Suicide rate per 100,000 people (age-adjusted, so years can be compared)13.7 in 2024, 14.1 in 2023, 14.0 in 20172024, final, CDC

Step 1, count the people with a condition: SAMHSA, the federal Substance Abuse and Mental Health Services Administration, gives the baseline. Its mental illness figures are model-based estimates, not direct diagnoses.

Step 2, count the people who get treatment: SAMHSA's treatment shares are shares of all adults, not of adults with a disorder. They count medication, telehealth and treatment in jail. SAMHSA says estimates for 2021 to 2023 are not comparable with 2024.

Step 3, read a second survey: The Centers for Disease Control and Prevention (CDC) asked about counseling or therapy and medication separately. Do not compare SAMHSA's 22.9% with the CDC's 14.0%, because the questions differ.

Step 4, the gap and the harm: About half of adults with any mental illness got treatment in 2022, but those data are not comparable with 2024. The harm shows up in deaths. Overdose deaths fell for a third year: 81,313 minus 69,973 is 11,340 fewer, or about 13.9% (11,340 divided by 81,313). The 2025 counts are provisional. The suicide rate fell from 14.1 in 2023 to 13.7 in 2024, but it has stayed roughly flat since 2017 (CDC, 2025 provisional data; CDC, 2024 final data).

Why it matters: about half of adults with any mental illness did not get treatment in 2022, so there are people who could use care. The data do not say how many of them live near your clinic or can pay for it. What to do: each month, count the people who ask for an appointment and the people you turn away or refer out.

How short is the workforce, and how hard is it to get an appointment?

The workforce is short, and new clients and patients wait. Four steps show it.

Step 1, the federal projection: HRSA, the federal Health Resources and Services Administration, counts shortages in full-time equivalents, where one equals one full-time worker. Its 2038 projection counts only the care people use today. On that basis, it projects shortages of about 99,840 psychologists, 99,780 mental health counselors and 77,050 addiction counselors (HRSA, 2038 projection). HRSA's page labels the addiction counselor group (MA) and does not say what the label means. Counting unmet need adds more for psychologists:

an additional 136,350 psychologists would be required by 2038 to meet all unmet need for psychologists

HRSA, Bureau of Health Workforce, Health Workforce Projections, reviewed December 2025.

The chart below shows the six projected shortfalls.

The data

By 2038 the U.S. is projected to be nearly 100,000 psychologists short

Mental health counselors are projected about as short, at 99,780.

  • Psychologists99,840
  • Mental health counselors99,780
  • Addiction counselors77,050
  • Psychiatrists43,810
  • School counselors39,680
  • Marriage and family therapists33,840

Full-time equivalents based on how much care people use today. The figures leave out unmet need.

2038 projectionSource: HRSA Health Workforce Projections

Step 2, where people live: As of September 30, 2026, HRSA counts 7,127 mental health shortage designations covering about 154.6 million people. They are 1,173 geographic areas, 960 population groups and 4,994 facilities. In these places, about 26% of the need is met (26.24% in HRSA's table). That means they have about 26 clinicians for every 100 they would need to meet the federal threshold for people per clinician.

HRSA says 7,796 more practitioners would be needed to remove every designation, and 4,311 of the designations (60.49%) are rural (HRSA, September 30, 2026). These count designations, not people or clinics.

Step 3, what patients meet: From May to July 2023, researchers phoned 320 offices of psychiatric prescribers (psychiatrists, nurse practitioners and physician assistants) in four cities. Each was listed in a Medicaid managed care directory (an insurer's list of clinicians for Medicaid members) as taking new patients. Only 87 offices (27.2%) had an appointment available with the sampled prescriber or a colleague. Median waits ran from 11 days in Phoenix to 64 days in Los Angeles (JAMA, 2024).

That covers prescribers only. For therapists, 46% of surveyed psychologists had no openings in 2025, down from 65% in 2021. Also, 40% had a waitlist, and 61% could see a new client within a month (American Psychological Association, 2025).

Step 4, who the workforce is: The U.S. Bureau of Labor Statistics (BLS) counts jobs, pay and growth for each group.

GroupJobs, 2025Median pay, May 2025Projected growth, 2025 to 2035Source (last modified August 27, 2026)
Psychologists209,400$99,1106%BLS
Substance abuse, behavioral disorder and mental health counselors (bachelor's-level and master's-level jobs are mixed)533,400$59,35018%BLS
Marriage and family therapists76,300$66,94014%BLS
Social workers (pay and growth are for all social workers)816,100, of whom 138,900 work in mental health and substance abuse$61,7806%BLS

BLS pay covers wage and salary workers only, not self-employed owners. The shortage figures above show fewer clinicians than the care people use today, so open appointment slots and clinician hours are limited. A clinic can start by measuring its own open slots and no-show rate.

How do behavioral health practices get paid in 2026?

Practices get paid through channels with different rules. Three subsections cover insurers and cash-pay clients, Medicare and Medicaid, and parity enforcement. Telehealth payment rules follow in the next major section, and networks that find clients and handle billing are covered with the software costs.

What do insurers pay, and why do 38% of psychologists take no insurance?

Psychologists who take no insurance, or who stopped taking a plan in the past year, name low pay (75%), payer paperwork (57%) and worries about payment reliability (43%). The table shows three sources.

SourceWhat it foundCaution
American Psychological Association, 2025 survey38% of licensed psychologists accept no health insurance. 55% take commercial insurance, 33% traditional Medicare and 20% traditional Medicaid. Top barriers, among those who take none or stopped taking a plan in the past year: insufficient reimbursement (75%), payer administrative issues (57%), concerns about payment reliability (43%).1,742 completed responses, 6.6% completion rate, self-reported
Health Affairs Scholar, 2023 listingsIn late 2023, 35.1% of 175,083 private-practice psychotherapists on Psychology Today accepted no insurance. The average listed cash rate was $143.26 a session. The average Medicaid fee for a 45-minute session was $82.77. The authors report Medicaid rates about 40% lower. The two averages differ by about 42% ($143.26 minus $82.77 is $60.49, and $60.49 divided by $143.26 is 0.42). So treat "about 40%" as approximate.Self-reported listing prices, not collected fees. Medicaid schedules last updated October 2022.
RTI International, 2021 employer-plan claimsBehavioral health office visits were out of network (outside the insurer's list of approved clinicians) 13.4% of the time, against 3.8% for medical or surgical visits. For the same services, in-network pay averaged 102.5% of what Medicare would pay for behavioral health clinicians and 124.8% for medical and surgical clinicians.Predates the 2024 parity rule. The Mental Health Treatment and Research Institute, a subsidiary of The Bowman Family Foundation, commissioned the work, and the American Psychiatric Association, the American Psychological Association and the National Association for Behavioral Healthcare paid part of the cost. Not current rates.

RTI International is a research group. The out-of-network gap works out to about 3.5 times (13.4 divided by 3.8).

The pay gap is 124.8 minus 102.5, or 22.3 points of Medicare's rate. RTI reports it as medical pay being 21.7% higher. Our rounded figures give about 1.22 (124.8 divided by 102.5). Before you accept or keep a spot on an insurer's panel (its list of approved clinicians), compare each payer's rate with your own cash rate.

Where do Medicare and Medicaid stand for 2026 and 2027?

CMS proposes a Medicare conversion factor for 2027 that is 1.68% lower for most clinicians, and states must generally start Medicaid work rules by January 1, 2027. CMS, the Centers for Medicare & Medicaid Services, pays Medicare clinicians relative value units (points for each service) times a dollar conversion factor. So the factor alone is not a session rate. The proposed 2027 factor is $0.56 lower than 2026 ($33.40 minus $32.84).

We cannot say what any psychotherapy code will pay, because relative values may also change. Medicaid is the joint federal and state program for people with low income. KFF is a nonprofit health policy research group.

TopicWhat the source saysSource and data year
Medicare, 2026The conversion factor is $33.40 for most clinicians, up 3.26%. For clinicians in qualifying alternative payment models, it is $33.57, up 3.77%. These models are CMS programs that pay for quality and cost, not only per visit. Behavioral health services are excluded from a new minus 2.5% efficiency adjustment.CMS, 2026
Medicare, 2027 (proposed)$32.84, down 1.68%, for most clinicians, and $33.17 for clinicians in those models, down 1.19%, because a one-time 2.50% increase for 2026 ends. No final rule was published as of October 6, 2026; it reached White House review on September 29, 2026.CMS, 2027 proposal
Medicaid coverage and ratesCovers nearly one-third of adults with mental illness and nearly one-quarter of adults with a substance use disorder. More than half of states raised fee-for-service rates for outpatient behavioral health providers in fiscal year 2024, and about half did in fiscal year 2025. About one quarter reported plans to raise them in fiscal year 2026. KFF's coverage shares come from earlier analyses. A June 2025 KFF brief put Medicaid's share of adults with a substance use disorder at about one-fifth, and we use the newer page.KFF, 2026; KFF, June 2025
CCBHCsA certified community behavioral health clinic (CCBHC) is paid a rate set for that clinic in advance, not a fee per visit. Nineteen states reported recognizing CCBHCs as an enrolled provider type in fiscal year 2025, up from nine in fiscal year 2022.KFF, 2026
CCBHC demonstrationOn May 28, 2026, the Department of Health and Human Services (HHS) selected 10 more states. They are Alaska, Colorado, Hawaii, Louisiana, Maryland, Mississippi, Montana, North Dakota, Washington and West Virginia. They start between July 1, 2026 and July 1, 2027. Medicaid.gov's background page puts the total at 30 selected demonstration states.CMS, 2026; CMS background
Medicaid work requirementsStates must generally start no later than January 1, 2027, and some start sooner. Adults aged 19 to 64 in the Medicaid adult group must show 80 hours a month of qualifying activity, such as work. The rule does not cover people who are pregnant or on Medicare. Exempt groups include people who are medically frail (their health conditions limit what they can do) and people in a drug or alcohol treatment program. The law's medically frail list includes a substance use disorder and a disabling mental disorder. Under the June 1, 2026 rule, each state builds its own list of qualifying conditions. The rule asks whether the condition significantly limits the person's ability to work or take part in qualifying activities. The substance use category applies whether or not the person is in a treatment program, but not to people in active recovery for 5 or more years.CMS, 2026; KFF, April 30, 2026; KFF, June 23, 2026

State plans for higher Medicaid rates may not happen. The June 1, 2026 work rule is an interim final rule: it took effect on July 31, 2026, the same day comments closed, and CMS can still revise it. If you see Medicare or Medicaid clients, count how many you have. Then estimate what a 1.68% lower Medicare conversion factor would cost you, and list the Medicaid clients who may need exemption paperwork before January 1, 2027.

What is happening with mental health parity enforcement?

Parity means health plans may not limit mental health and addiction benefits more strictly than medical benefits. In a joint court filing on September 30, 2026, the Departments of HHS, Treasury and Labor said they no longer defend the 2024 parity rule in court. They still do not enforce its new parts. The departments intend to send a replacement proposal to the White House regulatory review office on or before December 18, 2026. They expect that review to finish within 90 days (court filing, September 30, 2026).

Non-enforcement lasts until a final court decision plus 18 months, and the 2013 rule and the 2021 law still apply.

On September 8, 2026, the Department of Labor named three focus areas for employer plans. The first is blanket exclusions, where a plan refuses to cover a whole type of mental health or addiction treatment. The second is how plans review care: medical-necessity review (is the care needed?) and prior authorization (approval before care). The third is network adequacy, meaning whether a plan's list of clinicians is big enough for members to get care. It covers how plans admit clinicians and set their pay (Department of Labor, 2026).

This is an enforcement memo, not a rule. Because the Department of Labor is looking at these areas, written records of your denials, prior-authorization delays and out-of-network referrals are useful if you appeal or complain.

Which telehealth, prescribing and licensing rules apply in 2026 and 2027?

Telehealth is now a normal part of therapy, and its rules carry end dates. Five steps show where things stand.

Step 1, scale: In Epic Research's health-system data, 29.6% of encounters in mental health departments were telehealth in July 2026. That is the highest of the nine specialties the tracker lists, against 7.1% across all specialties (Epic Research, July 2026). That is about 3 in 10 mental health encounters, so remote visits are a normal part of care in these systems. But the figure comes from health systems that use Epic, an EHR vendor, and may not represent independent practices, so your own share may differ. Count last month's video visits to see yours.

Step 2, Medicare: Medicare pays for telehealth anywhere in the United States, including a patient's home, through December 31, 2027. CMS says:

Through December 31, 2027, beneficiaries can receive Medicare telehealth services anywhere in the United States and territories.

CMS, Telehealth FAQ (Updated 2/26/26), February 26, 2026.

After that date, a patient needs an in-person visit within 6 months before the first mental health telehealth service, then at least every 12 months. Patients who start mental health telehealth at home on or before December 31, 2027 do not need that first in-person visit. CMS calls them established, and they need an in-person visit at least once every 12 months after that date. This covers fee-for-service Medicare only (Medicare pays a set fee for each service). Medicaid and private payers set their own rules, limited exceptions exist, and Congress can change the dates.

Step 3, controlled medications: The Drug Enforcement Administration (DEA) and HHS extended the COVID-era telemedicine rules for controlled medications through December 31, 2026. Under these rules, a prescriber needs no prior in-person visit if the other conditions are met. This is the fourth temporary extension, and there is still no permanent rule. DEA sent a final special-registration rule to White House review on August 25, 2026, according to law-firm and trade reports, so one could replace the temporary rule before December 31 (DEA and HHS, 2025).

A separate rule covers buprenorphine, a medicine for opioid use disorder. It lets a DEA-registered prescriber start it by telemedicine, including audio-only for an initial six-month supply (DEA and HHS, 2025). DEA and HHS delayed its start twice, to December 31, 2025. The December 2025 notice says a prescriber may keep using the temporary rule even where the buprenorphine rule also applies, because the temporary rule has fewer requirements.

Step 4, licensing compacts: A compact is an agreement among states that lets a licensed clinician practice across state lines, and three apply here. Under the Counseling Compact, a privilege to practice is permission to see clients in another member state.

CompactProfessionStatusSource
Counseling CompactProfessional counselors10 states issuing privileges to practice as of October 1, 2026, with Oklahoma the 10th. Arizona and Minnesota went live on September 30, 2025, the first two. Pennsylvania became the 40th member when its governor signed on July 12, 2026. The compact's map page lists 40 members but still names only Arizona, Minnesota and Ohio as live. A counselor needs a home-state license and must hold a license or privilege where the client is.Counseling Compact news, October 1, 2026; go-live notice; map page
PSYPACTPsychologistsPSYPACT is the psychologists' licensing compact for telepsychology and temporary in-person practice. Final legislation is listed in 43 jurisdictions by our count of names, as the page gives no total. News items add Alaska (June 25, 2026) and Iowa (July 1, 2026), which are not in that list. Passing a law does not mean a state is operational.PSYPACT, 2026
Social Work Licensure CompactSocial workersEnacted in 35 states as of July 2026, per the compact's own news page. The Association of Social Work Boards (ASWB) counted 32 as of May 18, 2026. Multistate licenses are not yet issued. The compact's July 7, 2026 notice says the process will take about 18 to 24 months before social workers can apply. Its data system is due in Spring 2027. ASWB's May 2026 document said likely within 9 to 12 months. Both are forecasts.Social Work Licensure Compact, July 7, 2026; Association of Social Work Boards, May 2026

The two social work forecasts differ, so the timeline leaves them out. The timeline below puts the other dates from this section in order.

Timeline

Telehealth, prescribing and licensing dates run from 2025 to 2028

These dates can move if Congress or an agency acts again.

  1. Sep 30, 2025Done

    Arizona and Minnesota go live with the Counseling Compact

    The first two states to open applications for a privilege to practice

  2. Jun 25 and Jul 1, 2026 (news posted)Done

    Alaska and Iowa laws joining PSYPACT, the interstate agreement for psychologists

    PSYPACT posted news that Alaska (June 25, 2026) and Iowa (July 1, 2026) passed legislation, with effective dates of September 20, 2026 and July 1, 2027. Passing a law does not mean a state is operational

  3. Oct 1, 2026Done

    Oklahoma becomes the 10th state issuing Counseling Compact privileges

    Arizona and Minnesota began first, in September 2025

  4. Dec 31, 2026Coming

    Federal telemedicine rules for controlled medications end unless extended

    The Drug Enforcement Administration (DEA) and HHS rule is the fourth temporary extension, with no permanent rule yet; a final rule has been at White House review since August 25, 2026, per law-firm and trade reports

  5. Dec 31, 2027Coming

    Last day of Medicare home telehealth without the in-person visit rule

    Fee-for-service Medicare only

  6. Jan 1, 2028Coming

    In-person visit rule for home mental health telehealth starts

    An in-person visit within 6 months before the first service, then every 12 months

2025 to 2028Sources: CMS Telehealth FAQ · DEA and HHS fourth extension · Counseling Compact news · PSYPACT final legislation

Step 5, a caution: Do not assume telehealth lowers no-shows. In one rural Louisiana behavioral health system, telehealth appointments had a higher no-show rate (17%) than in-person ones (13%). The study covered 9,715 appointments from May 2022 to January 2023 (JAMA Network Open, 2023). It is one system, and patients who chose video may differ.

These rules carry end dates, so put them on a calendar and plan for each one.

Which rules on psychotherapy notes, substance use records and open notes matter most?

Five rules come first. This is general information, not legal advice, and state law can add more. "Under HIPAA" means under the federal health privacy law.

Rule 1, what counts: Under HIPAA, psychotherapy notes are notes that a mental health professional records to document or analyze a counseling session. The professional keeps them separate from the rest of the record. They exclude medication prescription and monitoring, session start and stop times, the types of treatment and how often they are given, and clinical test results.

Psychotherapy notes also exclude summaries of diagnosis, how well the patient manages daily life, treatment plan, symptoms, outlook (prognosis) and progress to date. So an ordinary progress note kept in the chart is not a psychotherapy note (HHS Office for Civil Rights, 2017). HHS says:

the Privacy Rule requires a covered entity to obtain a patient’s authorization prior to a disclosure of psychotherapy notes for any reason

HHS Office for Civil Rights, FAQ on extra protections for mental health information, content last reviewed September 12, 2017.

A covered entity is a clinic or clinician bound by HIPAA. With few exceptions, it needs the patient's authorization to disclose these notes, even to another treating provider. Exceptions include disclosures that other law requires, such as abuse reporting and cases where a clinician must warn a person at risk. State laws vary on whether a warning is required or only allowed.

The graphic also uses two terms from Rule 3. Open notes means patients can read their notes online. The federal information-blocking rules bar providers from unreasonably holding back electronic health information (EHI), which is the patient data a provider keeps in electronic form. The graphic below shows what the rules say about one such note: sharing it, patient access and open notes.

How it works

A psychotherapy note follows its own rules for sharing, access and open notes

The note must be kept separate from the rest of the chart to count.

  1. Definition

    A counseling session note

    Recorded to document or analyze a session and kept separate from the chart

    someone asks to share it
  2. Disclosure

    Sharing it

    Needs the patient's authorization, with few exceptions

    the patient asks to read it
  3. Access

    Patient access

    No right of access to these notes under the federal privacy law

    someone asks to post it online
  4. Online

    Open notes

    Not electronic health information, so the rule against blocking electronic records does not cover it

State law can add more.

HIPAA rules in force 2026Sources: HHS Office for Civil Rights FAQ · 45 CFR 164.524 · Understanding Electronic Health Information

Rule 2, patient access: Patients have no HIPAA right of access to psychotherapy notes. For the rest of the record, a clinician can deny access only on narrow grounds. The main one is a licensed professional's judgment that access is reasonably likely to endanger life or physical safety. A different licensed professional can review the denial (45 CFR 164.524). The listed grounds do not include emotional distress.

Rule 3, open notes: Under the information-blocking rules, psychotherapy notes are not EHI (Office of the National Coordinator for Health IT, 2026). So a clinic is not required to release psychotherapy notes to meet those rules.

An ordinary progress note kept in the chart is part of the designated record set, the group of records a clinic keeps about each patient. That set includes medical and billing records and records used to make decisions about the patient. So a progress note is EHI unless another exclusion or exception applies (Office of the National Coordinator for Health IT, 2026).

The Preventing Harm exception lets a clinician delay or withhold electronic information when a risk of harm is reasonably expected. The clinician must reasonably believe the step will substantially reduce that risk, and the step must be no broader than necessary. For a risk to one patient, a licensed professional with a current or past relationship with that patient must make the finding. The patient keeps any right to a review (45 CFR 171.201).

Rule 4, substance use programs: 42 CFR Part 2 is a federal rule that protects records of federally assisted substance use treatment. Programs it covers had to meet its 2024 update by February 16, 2026, so it now applies. One consent can now cover all future uses of a patient's records for care, billing and clinic operations. HIPAA's breach rules (telling people when their records are exposed) and HIPAA-style penalties now apply. Patients can also complain directly to HHS (HHS, 2026).

Substance use disorder (SUD) counseling notes are a new category and need their own consent. They cover only notes the clinician voluntarily keeps separate. HHS calls the protection analogous to the one HIPAA gives psychotherapy notes.

Rule 5, state law: HIPAA does not override a more stringent state privacy law. So rules on mental health records and minors' consent differ by state (45 CFR 160.203).

A note counts as a psychotherapy note only if it is kept separate from the chart. Decide on purpose what you keep apart, and confirm your software can store it apart.

What do the rules and professional groups say about AI in therapy?

Rules on AI in therapy come from states and professional groups. This is general information, not legal advice.

Step 1, state laws: Illinois, Nevada, Maine and Colorado limit AI that acts as the therapist, and Vermont and Rhode Island passed similar laws in June 2026, which the table leaves out because we did not read them in full. Utah sets rules for chatbots sold to the public. The table lists five AI laws we read. It adds California's recording law, because an AI note taker (software that listens to or reads a session and drafts the note) records sessions.

State and lawWhat it doesStatusPenaltySource
Illinois, Wellness and Oversight for Psychological Resources ActNo AI to provide therapy or make therapeutic decisions. Licensed professionals may use AI for administrative and supplementary support.Signed Friday, August 1, 2025 (HB1806); effective immediately on signature, per the August 4 releaseFine up to $10,000 per confirmed violationIllinois, press release, August 4, 2025 (we read the release, not the statute)
Nevada, AB 406Providers may not use AI directly in patient care. AI is allowed for administrative support such as scheduling, records, billing and session notes if the provider independently checks billing records and session notes.Effective July 1, 2025Unprofessional conduct for providers. Civil penalty up to $15,000 per violation for AI providers and unlicensed persons.Nevada, enrolled bill, 2025
Maine, LD 2082 (Public Law 2026, chapter 687)No offering therapy through AI unless a licensed professional provides it. Therapists may use AI for notes and supplementary support only under three conditions. The session is recorded or transcribed. The client is told in writing what the tool does and how data is stored, kept, used for training and deleted. The client consents. A therapist may not refuse care because a client declines AI.Signed April 13, 2026. The effective date is not in the text we read. A September 2026 register lists July 29, 2026, which we could not confirm on a legislature page.Board discipline, or a violation of the state's unfair trade practices lawMaine, chaptered text, 2026
Colorado, HB26-1195AI may interact with clients in therapeutic communication only when the professional, the AI and the client interact in real time. Advance disclosure and written informed consent are required when AI records or transcribes a session.Signed June 3, 2026. Effective August 12, 2026.Board discipline. Misleading claims that AI provides psychotherapy become a deceptive trade practice.Colorado, bill summary marked as enacted, 2026
Utah, HB 452Mental health chatbots must disclose that they are AI and may not sell or share identifiable health information. It does not regulate clinicians' note takers.Effective May 7, 2025. A September 2026 register says it was amended in 2026, and we did not read the amendments.Fines up to $2,500 per violationUtah, enrolled bill, 2025
California, Penal Code 632 (not an AI law)Recording a confidential communication without the consent of all parties is a crime. Federal law needs one party's consent. The statute does not mention AI note takers. We did not survey other states.In force, last amended effective January 1, 2017For a first offense, a fine up to $2,500 per violation, up to one year in county jail or state prison, or bothCalifornia Penal Code 632

Illinois, Maine and Colorado speak directly to AI note takers, and all three require written client consent when AI records or transcribes a session. Rhode Island's new law also requires written notice and consent. Nevada requires the provider to check AI-produced notes and billing records.

Step 2, the federal picture: We found no federal law that sets these rules. The table shows what federal bodies have said and done.

ItemWhat it saysSource and data year
Food and Drug Administration (FDA) briefing, November 6, 2025No AI-enabled medical device had been authorized for a mental health use. Fewer than twenty digital mental health devices, none of them AI, had been authorized. We did not verify any later authorization. On August 18, 2026 FDA posted a discussion paper on regulating generative AI-enabled devices, with comments due October 19, 2026. It is not guidance or policy.FDA, 2025; FDA discussion paper, August 18, 2026
Executive Order 14365, December 11, 2025Directs the Justice Department to challenge state AI laws and asks for a federal law that would override them. An executive order does not by itself override state laws.Executive Office of the President, 2025
Justice Department actionThe only action we found, on April 24, 2026, targets Colorado's separate algorithmic-discrimination law, not an AI therapy law.U.S. Department of Justice, 2026
House discussion draft, June 4, 2026Would keep state laws on the use of AI systems. It is a discussion draft, and we found no sign it has become law.Representative Trahan's office, 2026

Step 3, professional guidance: Each profession's group has said something about AI. None of this is law.

GroupWhat it saysNotesSource
American Psychological Association, ethical guidance for psychologists (June 2025, updated July 2025)Psychologists have an ethical duty to get informed consent about AI tools. Consider adding when, how and which AI tools are used to written consent. Tell clients they may opt out of certain AI-driven interventions.Not official policy and not mandatoryGuidance, 2025
American Psychiatric Association, resource document (July 2026)Tell patients about AI note takers, offer an opt-out and document consent. Use an AI platform that is HIPAA-compliant. It states that no FDA-approved AI application exists for psychiatric diagnosis, treatment or clinical decision-making.A resource document, not a position statementResource document, 2026
American Counseling Association (2024 recommendations)Get explicit informed consent for AI-assisted tools, avoid over-reliance and protect client data.Its 2014 ethics code is being revised. The National Board for Certified Counselors reported in January 2026 that adoption was targeted for fall 2026, with AI in supplemental guidelines. We found no published final code.Recommendations, 2024; Certified Counselors board, January 2026
American Association for Marriage and Family Therapy (code effective January 1, 2026)Standard VI requires informed consent and written notice of risks for technology-assisted services. It bars technology in place of the therapist's own treatment decisions.The code never uses the words artificial intelligenceCode of Ethics, 2026
National Association of Social WorkersAn eight-point ethics tip sheet, and a warning that AI tools can expose client data to third-party vendors.The page is undated, its newest dated items are from 2025, and we found no standalone 2026 AI standardAI and Social Work

The American Psychiatric Association's July 2026 document gives plain advice on note-taking tools:

Clinicians should inform patients about the use of the technology and provide an opt-out option. Consent should be documented.

American Psychiatric Association, Resource Document on Artificial Intelligence in Psychiatric Practice, July 2026.

Step 4, adoption and evidence: A JMIR Mental Health survey covered 766 professionals in 30 countries. It found that 54.6% (418) had used a generative AI tool in psychotherapy practice at least once. A generative AI tool is software such as ChatGPT that writes text. Only 18.1% reported institutional encouragement, and 81.1% had no AI training (JMIR Mental Health, 2026). It ran from January to March 2026, used a convenience sample and was not a U.S. sample.

The only large study of an AI note tool in mental health care we found is the platform's own. It covered 1,528 providers and over 286,000 notes, with 97.7% and 98.4% thumbs-up ratings, which are not an accuracy audit (JMIR Formative Research, 2026). In a survey, 201 U.S. adults recruited online, described as prospective patients, rated made-up therapy scenarios. A therapist using AI made therapy less acceptable and lowered the intent to continue. Secret use did worst, and telling clients reduced but did not remove the penalty (American Journal of Psychotherapy, 2026).

In at least six states whose laws limit AI therapy (Illinois, Nevada, Maine, Colorado, Vermont and Rhode Island), AI may help with administrative work under conditions. That is what the laws or official summaries we read say, and we read Vermont's and Rhode Island's, signed in June 2026, only in summary. The guidance asks for client consent. So tell clients in writing, get their consent and review every AI note yourself.

What is daily practice like: solo or group, income and burnout?

Mental health practice trends point to more small practices, growth in practices with employees and a modest average net income for sole proprietors. The table gathers the figures, and four steps explain them.

MeasureFigureData year and source
Psychologists naming private practice as their main setting64% (1,113 of 1,739). Of those in private practice as a main or second setting, 75% are solo and 25% are in a group.2025, American Psychological Association
Mental health practices with no paid employees249,151, up 10.1% from 226,306 in 2023 (249,151 divided by 226,306 is 1.101). Of these, 235,860 (about 95%) are sole proprietorships (235,860 divided by 249,151 is 0.947).2024, U.S. Census Bureau
Private mental health practitioner offices with employees54,453, up from 32,791 in 2022 (39,421 in 2023 and 46,404 in 2024). Average pay per employee $50,440, up from $47,778.2025, BLS
Sole-proprietor net incomeMean about $29,827 on mean receipts of $58,579, across 328,355 returnsTax year 2023, IRS
Gross receipts, practices with no employees42.4% under $25,000, 60.7% under $50,000, 16.7% $100,000 or more2024, U.S. Census Bureau
Burnout, licensed psychologists34% agree "I feel burned out" (1,655 answers), against 47.5% in 2021 and 31.8% in 2024. 51% of those within 10 years of their doctorate agree, against 16% of those 31 or more years out.2025, American Psychological Association; topline tables
Plans for weekly client hours17% decrease, 70% keep the same, 13% increase (1,684 answers)2025, American Psychological Association

Step 1, solo or group: In a 2025 survey, 75% of doctoral psychologists in private practice were solo, and 25% were in a group (American Psychological Association, 2025). Private practice could be a main or second setting. The Census counted 249,151 practices with no paid employees in 2024, and BLS counted 54,453 with employees in 2025. "No paid employees" is not the same as solo, because a contractor inside a group practice has none either.

Practices with employees grew about two-thirds in three years (54,453 divided by 32,791 is 1.66), while pay per employee rose 5.6% (50,440 divided by 47,778 is 1.056). From 2023 to 2024, BLS counted 39,421 then 46,404 practices with employees, which is 17.7% more (46,404 divided by 39,421 is 1.177). Census counted 10.1% more with no employees. The two programs count differently, so do not divide one count by the other. For example, Census County Business Patterns counted 46,513 offices of mental health practitioners with payroll in 2023, against BLS's 39,421, so compare years within one series.

Step 2, income: Net income was 50.9% of receipts ($29,827 divided by $58,579). The IRS totals give that mean: 9,793,988 thousand dollars of net income over 328,355 returns. These are sole proprietorships, which are businesses owned by one person with no separate company. The IRS row is offices of mental health practitioners and social therapists, and it counts psychiatrists in a separate row, include part-time practices and returns with losses, and give means, not medians.

A mean is the total divided by the number of returns. A median is the middle return. Census receipts are before expenses. The BLS wage survey leaves out the self-employed and owners of unincorporated firms:

The survey does not cover the self-employed, owners and partners in unincorporated firms, household workers, or unpaid family workers.

U.S. Bureau of Labor Statistics, Frequently Asked Questions (Occupational Employment and Wage Statistics), last modified July 9, 2026.

Step 3, burnout and hours: The 2021 and 2024 burnout figures are our sums of agree and strongly agree. The American Psychological Association changed its survey platform and sampling between years, so treat the trend as a rough guide. It is one agree-or-disagree question, not a validated burnout test, and the hours figures are plans, not later behavior.

Why it matters: a group practice that hires early-career clinicians should plan for burnout. In 2025, 51% of psychologists within 10 years of their doctorate said they feel burned out. Among those 31 or more years out, 16% did (American Psychological Association, 2025).

Step 4, caseloads: We found no national source for average caseload size or weekly client hours. The closest measures are 46% with no openings and 40% with a waitlist. BLS notes that counselors' workloads are large (BLS, 2026).

In 2024, 60.7% of practices with no employees took in under $50,000 in gross receipts (U.S. Census Bureau, 2024). For scale, take the solo therapist's first-year median software price from the cost section below: $1,027 without ClinikEHR. That is about 2% of $50,000 (1,027 divided by 50,000 is about 0.02).

Gross receipts include part-time practices and come before expenses, so the data do not show what owners keep or spend. A fixed cost such as software is a larger share of what an owner keeps than of receipts.

What does a behavioral health EHR cost, and what does it need to do?

A behavioral health EHR is software for charts, notes, scheduling and billing. Software is one of the therapy practice costs a clinic can compare line by line. The numbers below come from our EHR cost calculator for three practices. We read the prices on September 26, 2026, and they are before card fees.

Do behavioral health EHR vendors publish prices, and do clinics use them?

In our calculator, 24 of the 33 therapy and mental health EHRs publish a price (73%; 24 divided by 33 is 0.727). Of the 107 full EHRs in our calculator, 44 do (41%; 44 divided by 107 is 0.411) (EHR cost calculator, 2026). For addiction treatment and residential care, 3 of 9 publish a price (Opus EHR, ClinikEHR and BestNotes), so we give counts only. The table leaves out self-hosted free software and one-job tools.

In the tables, Full EHRs (n) and Vendors (n) give the number of vendors counted. Middle half is the price range left after setting aside the cheapest quarter and the dearest quarter of vendors. Quote only means the vendor shows a price only after you contact it. Enterprise contract means a custom contract for large organizations.

Practice type (full EHRs; prices read September 26, 2026)Full EHRs (n)Publish a priceQuote onlyEnterprise contractShare publishing a price
All practice types1074457641%
Therapy and mental health33249073%
Addiction treatment and residential care9360Counts only (fewer than 10 vendors)

Quote-only vendors (9 of 33 for therapy, 6 of 9 for addiction) sit outside every median below, so hidden prices may be higher. If a vendor you like is quote-only, get its price in writing before a demo.

On use, 68% of 1,680 surveyed psychologists used an electronic health record in 2025. Of the users, 49% did not know whether theirs is certified (American Psychological Association, 2025). In 2024, 68% of substance use and mental health treatment facilities used an EHR only. Another 25% mixed an EHR with paper charts, and 4% had no plans for one (Office of the National Coordinator for Health IT, 2024). That counts facilities, not solo practices.

What does a solo therapist pay each month?

Take a solo therapist with 1 clinician, 40 clients and about 110 sessions a month, with 70% billed to insurance (77 claims). The practice needs video visits, insurance claims, a client portal, online booking, text reminders, e-signature and intake forms. Of the 24 therapy EHRs with a published price, 8 have nothing missing, unpriced or unlisted on their pages for those features (7 without ClinikEHR). The other 16 each have at least one of those features unpriced, unlisted or not offered. One of them does not offer insurance claims.

Without ClinikEHR the median is $86 a month across 7 vendors with published prices in our calculator; with ClinikEHR, $87 across 8 (EHR cost calculator, 2026). ClinikEHR's price in the calculator is $130 a month. That is the Essential plan at $99.90 plus the usage charges and add-ons the calculator counts for this practice. It is the highest of the 8.

The first-year median is not 12 times the monthly median. The first year adds set-up fees and first-year rates, and a different vendor can sit in the middle. For example, 86 times 12 is 1,032, while the first-year median is $1,027.

Solo therapist scenario and features (monthly price before card fees; read September 26, 2026)PoolVendors (n)LowestMiddle halfMedianHighestFirst-year median
Essentials only: video visits, insurance claims, client portal, online bookingWithout ClinikEHR8$58$75 to $94$83$164$1,018
Essentials only: video visits, insurance claims, client portal, online bookingWith ClinikEHR9$58$77 to $111$86$164$1,027
Solo therapist: essentials plus text reminders, e-signature, intake formsWithout ClinikEHR7$58$76 to $90$86$111$1,027
Solo therapist: essentials plus text reminders, e-signature, intake formsWith ClinikEHR8$58$78 to $96$87$130$1,056
Solo therapist plus an AI note takerWithout ClinikEHR7$58$108 to $148$120$254$1,445
Solo therapist plus an AI note takerWith ClinikEHR8$58$108 to $147$125$254$1,513

ClinikEHR's figures are its plan price plus the other charges the calculator adds for that practice. The calculator lists each line. ClinikEHR's Essential plan includes its AI Note Taker for the first 3 clinicians, up to 300 minutes of audio a month pooled across the clinic. If every one of the solo therapist's 110 sessions were recorded, that is 2.7 minutes a session (300 divided by 110). The calculator does not price minutes beyond the allowance, so ClinikEHR's AI figures are not like for like with vendors that price every note.

The table shows three versions of the solo practice. Adding an AI note taker moves the middle price from $86 to $120 a month, a difference of $34 (120 minus 86). ClinikEHR's price is $115 for the four essentials and $130 for the other two versions. With AI notes, $130 is one of the middle values. In the seven-feature version it is the highest of the 8.

The chart below shows the spread for each version, for vendors without ClinikEHR. The dot marks ClinikEHR's own price.

The data

AI notes raise the middle price of a solo therapist's software from $86 to $120 a month

Monthly price before card fees, vendors without ClinikEHR. The dot marks ClinikEHR's own price.

  • Essentials only (4 features)8 products
    $83 middle$58 to $164ClinikEHR $115
  • Solo therapist (7 features)7 products
    $86 middle$58 to $111ClinikEHR $130
  • Plus AI notes (8 features)7 products
    $120 middle$58 to $254ClinikEHR $130

lowest to highestthe middle halfthe median (half cost less, half cost more)

Only vendors with a published price and nothing missing, unpriced or unlisted on their pages for those features are counted. Prices read September 26, 2026.

September 2026Source: ClinikEHR EHR cost calculator

Card fees come on top. Across the 14 therapy EHRs that charge the practice a published rate, the median is 3.35% of a $100 payment, from 2.60% to 4.50%. That leaves out Osmind, which passes the card processor's fee to the patient, and ClinikEHR. ClinikEHR has the highest online card fee in our calculator data: 5.10% on a $100 payment (a 1.9% platform fee plus Stripe's 2.9% + $0.30).

ClinikEHR's rate is a 1.9% platform fee plus the standard fee of Stripe, the company that processes the card payment. Stripe's standard fee is 2.9% plus $0.30. So 1.9% plus 2.9% is 4.8%, and the $0.30 adds 0.30% on a $100 payment. Another 8 of the 24 vendors have no card rate on file. Before you sign, ask each vendor for its card rate on a $100 payment and what it adds on top of the card processor's fee.

What do a five-clinician therapy group and an addiction clinic pay?

The group: Take a group with 5 clinicians, 1 admin, 200 clients and about 550 sessions a month. Of those, 70% are billed to insurance, which is 385 claims (550 times 0.70). It also needs outcome measures and group sessions. Only 5 vendors have nothing missing on their pages, 4 without ClinikEHR (EHR cost calculator, 2026). That is too few for a median, so the table names them.

Vendor (monthly price before card fees; read September 26, 2026)Monthly (no AI notes)First year (no AI notes)Monthly (with AI notes for the group)First year (with AI notes)
Zanda$318$3,861$413$5,001
Healthie$380$4,610$848$10,232
TheraPlatform$382$4,587$532$6,387
ClinikEHR (Team plan)$384$4,630$384$4,630
SimplePractice$551$6,609$726$8,709

Without AI notes, four of the five sit within $66 of each other ($384 minus $318), and SimplePractice is $551. With AI notes, the four vendors without ClinikEHR run from $413 (Zanda) to $848 (Healthie).

ClinikEHR's price stays at $384 because its Team plan includes the AI Note Taker for the first 5 clinicians. The allowance is 900 minutes of audio a month, pooled across the clinic. If every one of the group's 550 sessions were recorded, that is 1.6 minutes a session (900 divided by 550). The calculator does not price minutes beyond the allowance, so this row is not like for like with vendors that price every note.

Twelve therapy vendors charge an add-on or a higher plan for a five-clinician group. The median add-on is $188 a month, with a range of $75 to $625.

We could compare 21 therapy EHRs on entry plans (EHR cost calculator, 2026). Of these, 13 charge the same extra amount for each added clinician, and 8 charge a rate that changes with team size. None is flat. Entry plans include different things, and each added clinician brings 40 clients and 100 visits.

The medians leave out ClinikEHR, Halaxy and WriteUpp. Two vendors, ClinikEHR and Halaxy, have $0 plans for very small practices that do not bill insurance. With those two added, the median is $51 for one clinician and $219 for five (23 vendors).

Entry plan, no optional features, no claims (monthly price; read September 26, 2026)Vendors (n)LowestMiddle halfMedianHighest
1 clinician21$31$45 to $69$55$249
5 clinicians21$56$155 to $295$225$1,245
10 clinicians21$152$306 to $555$420$2,490

The addiction clinic: Take a clinic with 4 prescribing clinicians, 2 admin staff, 150 patients and about 600 visits a month. Of those, 60% are billed to insurance, which is 360 claims (600 times 0.60).

It needs e-prescribing, video visits, insurance claims, a patient portal, e-signature, outcome measures (questionnaires that track patient progress) and group sessions. It also needs EPCS and MAT. EPCS, electronic prescribing of controlled substances, means sending prescriptions for controlled medicines electronically. MAT, or medication-assisted treatment, means medicines such as buprenorphine given with counseling.

Only one vendor in our data has no gap recorded for these features, and it is ClinikEHR, the EHR we build. One vendor cannot make a median or a comparison, so we print no price for this clinic (EHR cost calculator, 2026). Opus EHR and BestNotes publish a price. Both pages leave at least one feature this clinic needs unpriced or unlisted, so a total for them would be too low. We do not print one.

Which features do therapy and addiction programs need, and which pricing pages list them?

We separate what a vendor's page states from what it leaves out. A feature that is offered is not always included in the price (EHR cost calculator, 2026). "Offer or include it" means the page says the vendor has the feature. "State it in the plan or price list" counts those that name the feature in a plan or price. "Only confirm it is offered" counts the rest.

"Limited" means the feature has a cap. "Offered, no price published" means the page says the feature exists but gives no price. "Not offered" means the page says the vendor lacks it. "Not listed" means the pricing page does not mention the feature, not that the vendor lacks it.

Feature (24 therapy EHRs with a published price; read September 26, 2026)Offer or include itState it in the plan or price listOnly confirm it is offeredLimitedOffered, no price publishedNot offeredNot listed
Outcome measures151050009
Group sessions181710006
Separate, restricted counseling and sensitive records11000023
Medication-assisted treatment (MAT)10110022
Residential care30300021
Insurance claims131300614
AI notes161602402

The next table gives the same counts for the 3 addiction EHRs with a published price. With only 3 vendors, we show counts and no shares.

Feature (3 addiction EHRs with a published price; counts only)Offer or include itState it in the plan or price listOnly confirm it is offeredLimitedOffered, no price publishedNot offeredNot listed
Outcome measures3300000
Group sessions3300000
Insurance claims1100200
E-prescribing of controlled substances (EPCS)1100200
E-prescribing2200100
Medication-assisted treatment (MAT)1011001
Residential care2020001
Separate, restricted counseling and sensitive records1100002
AI notes0001200

Three therapy rows stand out. Only 1 of the 24 lists separate, restricted counseling and sensitive records, a calculator feature that is not the HIPAA definition of psychotherapy notes. For MAT, 22 of 24 do not list it. For insurance claims, 13 state a price and 6 offer it with no published price.

Among the 3 addiction vendors, claims and controlled-substance e-prescribing are priced by 1 and offered with no price by 2. These features tie back to the rules above. Separate records link to the psychotherapy-note and Part 2 consent rules, controlled-substance prescribing to the telehealth dates, and AI notes to the consent rules.

For AI notes, 3 of the 24 therapy EHRs include them at no extra cost: Carepatron, Halaxy (on its video visits) and Blueprint. Two include only a capped allowance: ClinikEHR (up to 300 pooled audio minutes a month on Essential, 900 on Team) and Noterro (300 credits a month, about 18 minutes of recording, then $0.17 a minute).

Thirteen charge an add-on or a higher plan, with a median add-on of $35 a month and a range of $15 to $175. Four offer AI notes with no published price, and 2 do not list them.

For the five-clinician group, the split is the same across 23 vendors, except that 12 charge an add-on or a higher plan. WriteUpp, which has no published price at some team sizes, is in the solo count but not the group count. The chart below shows both splits.

The data

Three of 24 therapy EHRs include AI notes at no extra cost, and two cap the allowance

The rest charge extra for AI notes or do not state a price.

  • Solo therapist24 vendors

    3 included at no extra cost · 2 capped allowance · 13 paid add-on or higher plan · 4 offered, no published price · 2 not listed on the page — Halaxy's included notes apply to its video visits

  • Five-clinician group23 vendors

    3 included at no extra cost · 2 capped allowance · 12 paid add-on or higher plan · 4 offered, no published price · 2 not listed on the page

Therapy EHRs with a published price: 24 for the solo therapist and 23 for the five-clinician group, because WriteUpp has no published price at some team sizes. Capped allowance: Noterro (300 credits a month) and ClinikEHR (300 pooled audio minutes a month on Essential, 900 on Team); the calculator does not price extra minutes.

September 2026Source: ClinikEHR EHR cost calculator

Ask each vendor to state in writing that it offers a feature and what it costs.

Is an insurance network a substitute for practice software?

Only partly. Networks and staffing models such as Headway, Alma, Rula, Grow Therapy and SonderMind are not software. They bring clients and insurance contracts, handle billing and credentialing (the paperwork that gets a clinician approved by insurers), and include their own EHR. But none of them publishes what it keeps of each insurance payment, so a network is not a like-for-like swap for software. We keep networks out of every price median and show them in a separate, unranked panel in the calculator.

Talkspace's pages blocked our checks. Octave is a group practice that pays by the hour, and Spring Health publishes no fees or pay rates, so we leave them out. The tables show what each network publishes on its own pages.

NetworkJoining or membershipFee on private-pay or cash sessionsWhat it keeps of each insurance paymentSources
Headway$0 to join. From October 8, 2026 in five states, and every state by the end of 2026, $9.99 per appointment with a client who finds you through its marketplace, deducted from your payout2.95% of the session rate on card paymentsNot published. Headway describes a small percentage that varies by plan and billing code.Provider page; Rates and agreements; Private pay; Using insurance; AI notes; CPT code changes; Exporting records; Marketplace service fee
AlmaA paid membership: $125 a month month-to-month, or $95 a month billed as $1,140 a year; one landing page advertises $600 for the first year (Alma's provider pages, read October 6, 2026)2.4% + $0.30 per invoice. Alma takes no cut of cash-pay sessions.Not stated. Per-session rates are confidential.Provider page; Insurance page; Savings calculator; FAQ; Membership overview
Rula$0Not statedNot published. Pay rates are set from its payer contracts.Provider page; Pay rates; Accepted insurances; Medicaid by state
Grow TherapyNone stated on Grow's pages5% processing fee on cash-pay sessions. Clinicians are paid only after the client has paid.Not publishedProvider page; Cash-pay policy; Payor rates; Invoice and note requirements
SonderMindNot stated on its public pages.Not statedNot published. It says it pays the full contracted amount per session.Join page; Pay guarantee

The next table shows what each network includes and what it asks of you.

NetworkIts own EHRAI notesCredentialingYour records and clientsPayers it names
HeadwayAn all-in-one EHR with scheduling and documentationFree, for one-on-one talk therapy over Headway's own video only. Not for prescribers.Free, in as few as 30 daysDownload client records from the provider portal. Psychological testing codes cannot be billed through Headway.70 or more insurance partners, and only select Medicare Advantage (Medicare plans run by private insurers) and Medicaid managed-care (Medicaid run through private insurers) plans
AlmaAlma's EHR is included, and using it is optionalAI-assisted progress notes, listed with the membership's EHR tools, with no separate price statedRequired for new members, under Alma's tax IDReferrals that come through Alma must stay with AlmaCommercial plans. Its help center says it does not accept Medicare or Medicaid.
RulaRula's EHR, which clinicians must useA recap tool drafts notes from the session, for individual therapy onlyRula handles credentialing and enrollmentRula keeps the clients' records, and clinicians may not download, print or distribute them. Clients referred by Rula cannot be moved to your own practice.About 30 carriers are named, with managed Medicaid live in California, Hawaii, Minnesota and Virginia
Grow TherapyRequired for therapists who joined on or after May 5, 2025Pre-fills notes when both clinician and client consentGrow handles credentialingPayer enrollment does not transfer outside Grow. All payments for Grow clients go through Grow and Stripe.125 or more insurance partners, including Medicare and Medicaid

None of the five publishes what it keeps of each insurance payment, although Headway now publishes a $9.99 per-appointment fee for marketplace clients. Per-session rates are shown only inside provider portals or are confidential, so we do not estimate them.

The trade-offs differ. Rula's EHR is required and Rula holds the records. Alma asks that referrals it sends stay in its network. Grow's payer enrollment will not transfer outside Grow, and Headway lets you download records. We do not rank them.

A software bill is one number you can read today. What a network keeps of each insurance payment is not published, so ask for it in writing.

What This Means for Your Clinic: What Should You Do Now?

These seven steps turn dated rules and measured costs into decisions for this quarter.

  1. Put the dates on a calendar: December 31, 2026 (DEA telemedicine prescribing) and January 1, 2027 (Medicaid work requirements). Add December 31, 2027 (Medicare home telehealth) and January 1, 2028 (its in-person visit rule). Decide who would provide that visit. Why: each date comes from a rule that can change (CMS, 2026; DEA and HHS, 2025).
  2. Compare each payer's rate with your cash rate, and log denials, prior-authorization delays and out-of-network referrals. Why: the Department of Labor says it is looking there (Department of Labor, 2026). Also, cash rates averaged $143.26 against $82.77 for Medicaid in a 2024 study of 2023 listings (Health Affairs Scholar, 2024).
  3. If you serve Medicaid clients or run an addiction program, plan paperwork for exemptions and renewals before January 1, 2027, and check whether your state is adding CCBHCs. Why: states must start work requirements by then, though HHS may give a state a good-faith delay that ends no later than December 31, 2028 (CMS, 2026), and 10 more states were selected for the CCBHC demonstration in 2026 (CMS, 2026).
  4. Decide what you keep as psychotherapy notes, keep them apart from the chart, and check that your software can store them apart. Part 2 programs should check consent forms and breach steps against the update that has applied since February 16, 2026. Why: a note is a psychotherapy note only if it is kept separate (HHS Office for Civil Rights, 2017).
  5. Before you use an AI note taker, tell clients in writing, get their consent and read every AI note before you sign. Check your state's recording and AI rules. Why: Illinois, Maine, Colorado and Rhode Island require consent, and California needs all parties' consent to record (Colorado, 2026).
  6. Price software on your own numbers: ask each vendor to state every feature you need and its price in writing. Ask any network what it keeps of each insurance payment. Why: a median describes only vendors that publish prices. For a solo therapist it is $86 a month across 7 vendors with published prices in our calculator, without ClinikEHR ($87 across 8 with it). Only 8 of 24 therapy EHRs with a published price have nothing missing, unpriced or unlisted on their pages for the features we picked (EHR cost calculator).
  7. Protect capacity and safety: track no-shows and open slots, let clinicians weigh in on caseload and hours, and keep a written crisis plan. Why: 34% of psychologists feel burned out and 17% plan to cut client hours. The suicide rate has been roughly flat since 2017 (American Psychological Association full report, 2025; American Psychological Association topline tables, 2025; CDC, 2024).

What We Still Do Not Know

  • The 2025 National Survey on Drug Use and Health: SAMHSA released it in July 2026, but its pages blocked our tools. A state provider group's repost gives 20.6% of adults (54.6 million) with any mental illness. It gives 6.9% (18.2 million) with serious mental illness (Rehabilitation and Community Providers Association, 2026). A nonprofit summary gives 44.6 million people (15.3%) with a substance use disorder (Addiction Policy Forum, 2026).
  • Comparing 2024 and 2025: In 2024 the figures were 23.4%, 5.6% and 48.4 million (16.8%). Any mental illness fell while serious mental illness rose, which may be a method change, so we do not compare years.
  • Caseloads: We found no national source for average caseload size or weekly client hours.
  • What networks keep: What each network keeps of insurance payments is not published, so we do not estimate it.
  • Dates and rates that can change: The commercial pay gap data are from 2021 and predate the 2024 parity rule. The 2027 Medicare factor is a proposal, and we found no final rule. We cannot say what any psychotherapy code will pay. Medicare and DEA telehealth dates can change again.
  • More state laws: A continuing-education register published September 12, 2026 lists 2026 laws in Vermont, Rhode Island and Tennessee that we did not read. It also gives an effective date for Maine's law and 2026 changes to Utah's law. We could not verify these on a legislature page (psychology.com, September 12, 2026). Congress or the courts may change the picture.
  • Hidden prices: Vendors with quote-only pricing sit outside every price median, so the true market median may be higher.

Frequently Asked Questions

How many Americans get mental health treatment?

In 2024, 22.9% of adults (60.1 million) received mental health treatment and 3.6% (9.4 million) received substance use treatment, shares of all adults, according to SAMHSA. A CDC survey found 14.0% saw a professional for counseling or therapy and 19.3% took medication. In 2022, about half of adults with any mental illness got treatment. The surveys measure treatment differently, so do not compare them.

Is there a therapist shortage in 2026?

HRSA counted 7,127 mental health shortage designations (places, groups and facilities) covering about 154.6 million people as of September 30, 2026. It projects 2038 shortfalls of about 99,840 psychologists and 99,780 mental health counselors, based on today's use of care. In 2025, 46% of surveyed psychologists had no openings for new patients and 40% had a waitlist, according to the American Psychological Association survey.

Will Medicare keep paying for telehealth therapy?

Medicare pays for telehealth anywhere in the United States, including home, through December 31, 2027. After that, home-based mental health telehealth needs an in-person visit within 6 months before the first service and then at least every 12 months. Patients who start before January 1, 2028 skip the first in-person visit but need one in-person visit every 12 months. Congress can change the dates, and Medicaid and private plans set their own rules.

What are psychotherapy notes under HIPAA, and are progress notes the same?

Psychotherapy notes are a mental health professional's notes that document or analyze a counseling session and are kept separate from the rest of the record. A progress note kept in the chart is not one. They need patient authorization before disclosure, with few exceptions, carry no HIPAA right of access, and are not electronic health information under the information-blocking rule. Check state law. This is general information.

Can therapists use AI note takers in 2026?

In at least six states whose laws limit AI therapy (Illinois, Nevada, Maine, Colorado, Vermont and Rhode Island), AI may help with administrative work under conditions. That is what the laws or official summaries we read say, and we read Vermont's and Rhode Island's, signed in June 2026, only in summary. Illinois, Maine and Colorado require client consent when AI records or transcribes a session, as does Rhode Island's new law, and Nevada requires you to check AI-produced notes and billing records. Recording laws vary, and California needs all parties' consent. Professional guidance asks for informed consent, so check your state.

What do therapist private practice statistics say about income?

For tax year 2023, IRS data show a mean net income of about $29,827 per sole-proprietor mental health return, against mean receipts of $58,579, about half. Census data for 2024 show 42.4% of practices with no employees took in under $25,000 in gross receipts. Both include part-time practices. BLS wage tables exclude the self-employed, so they are not owner income.

How much does therapy practice software cost per month?

In our calculator, a solo therapist's median is $86 a month across 7 vendors with published prices without ClinikEHR ($87 across 8 with it). With an AI note taker it is $120 across 7 ($125 across 8). For a five-clinician group, the 5 vendors with nothing missing on their pages run from $318 to $551. We read the prices on September 26, 2026, before card fees.

Is it better to take insurance or go private pay?

The data cannot say which is better. In 2025, 38% of surveyed psychologists took no insurance, naming low pay, payer paperwork and payment reliability. A 2024 study of 2023 listings found a $143.26 average cash rate against $82.77 for Medicaid. Networks such as Headway, Alma, Rula and Grow publish fees for cash-pay sessions or joining. None publishes what it keeps of insurance payments, so compare your rate for each payer.

Conclusion

The state of behavioral health practice in 2026 is high need, short supply and rules that carry dates. In 2024, 14.0% of adults saw a therapist or counselor, and in 2025, 46% of surveyed psychologists had no openings. Payment and telehealth rules move on dates from December 31, 2026 to January 1, 2028, and a proposed Medicare change and Medicaid changes land in 2027.

Psychotherapy notes and substance use records have special protection under HIPAA and 42 CFR Part 2. AI tools can help with paperwork if you tell clients, get consent and check every note. Income for the smallest practices is modest, with a mean net income of about $29,800 per sole-proprietor return in 2023. So compare payer rates and software prices line by line, in writing.

ClinikEHR is the EHR we build. Its public pricing page lists a Free plan at $0 for up to 50 clients and 2 staff, with no card needed. Essential is $99.90 a month and Team is $250 a month, month to month. You can compare it with other products in the EHR cost calculator.

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Statistics are as of the dates shown. Check the linked sources for updates. This is general information, not legal or medical advice.

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