How to fax a coordination of care letter to a client's doctor
A therapist may fax a coordination of care letter to a client's doctor without authorization under 45 CFR 164.506(c)(2); psychotherapy notes need an authorization first.

A therapist may fax a coordination of care letter or treatment summary to a client's physician or psychiatrist without the client's authorization, because HIPAA counts coordination and consultation as treatment (45 CFR 164.506(c)(2)). Psychotherapy notes need an authorization, and each professional code sets its own consent rule for sharing with another professional.
Can a therapist fax a coordination of care letter without the client's authorization?
A therapist covered by HIPAA can fax a coordination of care letter to another provider for that provider's treatment without the client's authorization, because 45 CFR 164.506(c)(2) permits disclosures for the treatment activities of a health care provider.
45 CFR 164.501 defines treatment to include the coordination or management of health care by a provider with a third party, consultation between providers about a patient, and the referral of a patient from one provider to another. The minimum necessary standard does not apply to disclosures to a health care provider for treatment, under 164.502(b)(2)(i). The CMS fact sheet HIPAA Basics for Providers says providers can share information with doctors, hospitals and ambulances for treatment, payment and health care operations even without a signed consent form from the patient.
The treatment permission carries its own limit. Section 164.506(a) leaves out uses and disclosures that need an authorization under 164.508(a)(2) through (4), and the first of those, 164.508(a)(2), covers psychotherapy notes. A disclosure for another provider's payment activities, which 164.506(c)(3) also permits, keeps the minimum necessary standard: reasonable efforts to limit the information to the minimum necessary for the purpose (164.502(b)(1)). A separate guide answers whether you need patient consent to fax medical records.
The table sets each kind of recipient beside the rule that lets the letter go.
| Sent to | What it is | Authorization needed? | Rule | Official source |
|---|---|---|---|---|
| A treating physician or psychiatrist | A coordination of care letter or treatment summary for treatment | No | Treatment includes coordination, consultation and referral; disclosure for another provider's treatment is permitted; minimum necessary does not apply | 45 CFR 164.501, 164.506(c)(2), 164.502(b)(2)(i) |
| The primary care or attending physician, under Medicare's consultation agreement | A consultation, or a notice that the psychologist or clinical social worker is furnishing services | No HIPAA authorization; the patient's assent to consultation, with the dates documented | Tell the patient consultation is desirable, attempt it with the patient's assent, notify the physician if attempts fail, document the dates and manner | 42 CFR 410.71(e), 410.73(c) |
| Anyone, when the letter includes psychotherapy notes | Psychotherapy notes | Yes | An authorization for any use or disclosure, apart from listed exceptions such as the originator's own use for treatment; a consent under 164.506(b) cannot stand in for it | 45 CFR 164.508(a)(2), 164.506(b)(2) |
| A treating provider, for Part 2 records | Substance use disorder treatment records | Yes: the patient's written consent under Part 2 | One consent may cover all future treatment, payment and health care operations; each disclosure carries a copy of the consent or a clear explanation of its scope | 42 CFR 2.31, 2.33 |
| A family member involved in the client's care | Information for someone the client identifies as involved in their care | No, unless the patient objects | A provider can give information to family, friends or anyone the patient identifies as involved in their care | CMS HIPAA Basics for Providers |
What goes in a coordination of care letter, and what stays out?
A coordination of care letter can carry everything HIPAA's definition leaves out of psychotherapy notes: medication prescription and monitoring, session start and stop times, the modalities and frequencies of treatment, results of clinical tests, and summaries of diagnosis, functional status, the treatment plan, symptoms, prognosis and progress to date (45 CFR 164.501).
A summary built from those items falls outside the psychotherapy notes definition, and the treatment permission covers it. The notes themselves stay out: psychotherapy notes are the notes a mental health professional records to document or analyze the conversation in a private, group, joint or family counseling session and keeps separate from the rest of the record. Any use or disclosure of them needs an authorization under 164.508(a)(2), apart from the exceptions it lists, such as use by the originator of the notes for treatment. For the definition in full, see what HIPAA counts as psychotherapy notes.
A general consent does not fill that gap. A covered entity may obtain the client's consent for treatment, payment or health care operations; under 164.506(b)(2), that consent does not permit a disclosure that needs an authorization. An authorization contains at least the core elements of 164.508(c)(1), including the client's signature and date, and is not valid if a required element is left incomplete. A personal representative who signs adds a description of the authority to act for the client.
HIPAA's minimum necessary standard does not apply to a disclosure to a provider for treatment, and the codes set their own limits. ACA B.2.e says that when circumstances require disclosure of confidential information, only essential information is revealed. AAMFT 2.8 has a marriage and family therapist consulting with colleagues or referral sources share only what the consultation needs.
Does Medicare require psychologists and social workers to contact the client's doctor?
Medicare requires a clinical psychologist who bills Part B to agree, by signing Form CMS-855I, to tell the patient that consulting the primary care or attending physician is desirable, to attempt that consultation with the patient's assent, and to notify the physician if direct attempts fail, unless that physician referred the patient (42 CFR 410.71(e)). Both the attempt and the notice come within a reasonable time.
42 CFR 410.73(c) applies the same consultation requirements to clinical social workers, reading clinical psychologist as clinical social worker. The psychologist documents in the medical record the date the patient consented or declined consent to consultation, the date of consultation, or, if the attempts did not succeed, the date and manner of notification to the physician.
Chapter 15 of the Medicare Benefit Policy Manual says the agreement is contingent on the patient's consent and calls for the attempt "in accordance with accepted professional ethical norms, taking into consideration patient confidentiality." The manual names one exception: a patient whose primary care or attending physician referred the patient to the clinical psychologist. Chapter 10 of the Medicare Program Integrity Manual says signing Form CMS-855I indicates agreement to the requirements of 410.71(e)(1) through (e)(3). Medicare's mental health coverage booklet puts the first step plainly: unless the primary care or attending physician referred the patient, tell the patient you would like to consult their physician.
Which billing codes cover care coordination and written reports?
CMS's booklets list these codes for coordination and written reports: HCPCS G0323 for care management of behavioral health conditions, which includes coordinating with and referring to physicians and practitioners whom Medicare authorizes to prescribe medications and provide E/M services; the interprofessional consultation codes, such as G0546 and G0550; and CPT 90889 for preparing a report of the patient's psychiatric status, history, treatment or progress.
CMS's behavioral health integration booklet describes G0546 as 5 to 10 minutes or more of medical consultative discussion and review, including a verbal and written report, and G0550 as 5 minutes or more of medical consultation with written report. CMS says these interprofessional consultation codes allow billing by clinical psychologists, clinical social workers, marriage and family therapists and mental health counselors. To bill them, CMS requires the patient's consent to be documented in the medical record. CPT 90889 appears in the code list of Medicare's mental health coverage booklet.
What changes for substance use disorder records?
Substance use disorder records covered by 42 CFR Part 2 need the patient's written consent before a coordination letter carries them, and one consent may cover all future treatment, payment and health care operations (42 CFR 2.31).
The consent may be paper or electronic, and electronic signatures are permitted to the extent applicable law does not prohibit them. For that single consent, the recipient may be described as "my treating providers, health plans, third-party payers, and people helping to operate this program" or a similar statement, and "end of the treatment" or "none" is a sufficient expiration.
Under 42 CFR 2.33, each disclosure made with the patient's written consent must be accompanied by a copy of the consent or a clear explanation of its scope. A covered entity that receives the records under that consent may further disclose them as the HIPAA regulations permit. The notice wording for a faxed Part 2 record is on whether you can fax substance use disorder records.
What do the ACA, AAMFT and NASW codes add before a letter goes out?
The ACA, AAMFT and NASW codes each set their own consent rule for a letter to another professional: a counselor gets the client's written permission under ACA B.6.g unless exceptions to confidentiality exist, an MFT needs written authorization or waiver under AAMFT 2.2 unless law mandates or permits the disclosure, and a social worker may disclose with valid consent under NASW 1.07(b).
The table quotes each standard as its code states it.
| Code | Standard | What it says |
|---|---|---|
| ACA Code of Ethics | B.6.g | Unless exceptions to confidentiality exist, counselors obtain written permission from clients to disclose or transfer records to legitimate third parties |
| ACA Code of Ethics | B.2.e | When circumstances require the disclosure of confidential information, only essential information is revealed |
| ACA Code of Ethics | B.3.b | When an interdisciplinary or treatment team takes part in a client's services, the client is informed of the team's existence and composition |
| ACA Code of Ethics | B.3.e | Counselors take precautions to ensure the confidentiality of all information transmitted through any medium |
| AAMFT Code of Ethics | 2.2 | Marriage and family therapists do not disclose client confidences except by written authorization or waiver, or where law mandates or permits it |
| AAMFT Code of Ethics | 2.8 | When consulting with colleagues or referral sources, no sharing of confidential information that could reasonably lead to the identification of a client without written authorization; only what the consultation needs |
| NASW Code of Ethics | 1.07(b) | Social workers may disclose confidential information when appropriate with valid consent from a client or a person legally authorized to consent for the client |
| NASW Code of Ethics | 1.07(d) | When feasible, social workers should inform clients about a disclosure and its potential consequences before disclosing |
| NASW Standards for Technology in Social Work Practice | 3.07 | Reasonable steps to protect confidentiality when sharing client information electronically; the interpretation lists having the correct fax number and double-checking addresses before sending |
HIPAA's treatment permission and each code's consent rule are separate texts. The full codes are the ACA Code of Ethics, the AAMFT Code of Ethics and the NASW Code of Ethics.
How do you send the letter safely and prove it arrived?
A coordination of care letter goes by fax safely under the safeguards HIPAA already requires: 45 CFR 164.530(c) calls for administrative, technical and physical safeguards for protected health information, and CMS's HIPAA fact sheet lists fax machines, beside email and phone, among the ways providers can reach other health care professionals with safeguards in place.
Section 164.530(c) also has covered entities reasonably safeguard information from uses or disclosures that violate the Privacy Rule, and limit incidental disclosures made under a permitted one. CMS's fact sheet adds that records holding PHI stay out of reach of people who do not need to see them, and ACA B.3.e has counselors take precautions for information sent through any medium.
Social workers have the destination check in writing: the interpretation of NASW's technology Standard 3.07 (Standards for Technology in Social Work Practice) lists having the correct fax number among the ways to manage risk and says social workers should double-check addresses before sending.
A fax delivery record shows the date a letter reached the physician's number. Under 42 CFR 410.71(e)(3), a psychologist whose attempts to consult did not succeed documents the date and manner of notification to the physician, and a delivery record carries both. For other records going to a treating provider, see how to fax medical records to another provider.
How do you send coordination letters from a HIPAA fax account?
A coordination letter on Fax Pigeon goes out from the browser or from email as a PDF or a Word file, with an optional cover sheet, and every delivered fax gets delivery proof for the client's record. A faxed reply arrives at the practice's own number on any paid plan, in a shared inbox with roles and assignment. Every plan includes a signed BAA at signup and unlimited people. Plans start at $4.99 a month billed annually for 200 pages.
* Official sources (the Code of Federal Regulations at govinfo.gov, CMS, the ACA, AAMFT, NASW) were read on October 20, 2026. Fax Pigeon prices and plan terms as of October 21, 2026.
Frequently asked questions
- Do I need a client's authorization to send a coordination of care letter to their doctor?
- A therapist needs no HIPAA authorization to send a coordination of care letter to a client's doctor for treatment, because 45 CFR 164.506(c)(2) permits disclosures for another provider's treatment and HIPAA defines treatment to include coordination of care. Psychotherapy notes are the exception and need an authorization. Each code sets its own rule: ACA B.6.g asks counselors for written permission unless exceptions to confidentiality exist.
- Can a therapist send a treatment summary without sending psychotherapy notes?
- A therapist can send a treatment summary without psychotherapy notes, because HIPAA's definition of psychotherapy notes leaves out summaries of diagnosis, functional status, the treatment plan, symptoms, prognosis and progress to date, along with medication monitoring, session times, modalities and test results (45 CFR 164.501). A summary built from those items falls outside the definition. The notes themselves need an authorization under 164.508(a)(2).
- Does Medicare require psychologists to contact the patient's primary care doctor?
- Yes, unless that physician made the referral: a clinical psychologist who bills Part B agrees, by signing Form CMS-855I, to tell the patient a consultation with the primary care or attending physician is desirable, to attempt it with the patient's assent within a reasonable time, and to notify the physician if direct attempts fail (42 CFR 410.71(e)). 42 CFR 410.73(c) applies the same requirements to clinical social workers.
- Can therapists bill Medicare for coordinating care with a primary care doctor?
- Therapists can bill Medicare for some consultation work: CMS says its interprofessional consultation codes, such as G0546 with a verbal and written report and G0550 with a written report, allow billing by clinical psychologists, clinical social workers, marriage and family therapists and mental health counselors. CMS requires the patient's consent documented in the medical record to bill them, and describes G0323 care management as including coordination with prescribing physicians.
- What should a coordination of care letter include?
- A coordination of care letter can carry the items HIPAA keeps outside psychotherapy notes, such as medication monitoring, clinical test results and summaries of diagnosis, the treatment plan and progress to date (45 CFR 164.501), and minimum necessary does not limit a disclosure to a provider for treatment. The codes set their own limits: under ACA B.2.e only essential information is revealed when circumstances require disclosure, and AAMFT 2.8 has an MFT share only what a consultation needs.
- Can I fax substance use disorder treatment information to a client's doctor?
- Yes, Part 2 substance use disorder records can go to a client's doctor with the patient's written consent, given on paper or electronically, and a single consent may cover all future treatment, payment and health care operations (42 CFR 2.31). Each disclosure under that consent travels with a copy of it or a clear explanation of its scope (42 CFR 2.33), and a covered entity that receives the records may redisclose them as HIPAA permits.
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