Who checks what: consultation report, application, expert review — and two deadlines that many do not know
The application system is considered the most thankless part of the profession. One reason for this is that four different procedures are given the same name in everyday life: “the paperwork”. In fact, they are four procedures with four different purposes and very different consequences when something goes wrong.
A second reason is added: the detailed rules that are decisive for this procedure are found in two places. The Psychotherapy Directive (Psychotherapie-Richtlinie) of the Federal Joint Committee describes the procedure; the Psychotherapy Agreement (Psychotherapie-Vereinbarung) between the National Association of Statutory Health Insurance Physicians and the National Association of Statutory Health Insurance Funds (GKV-Spitzenverband) specifies it. Anyone who reads only one of the two overlooks deadlines — and that is not a theoretical danger, as the section on conversion shows.
Four procedures, not one
The consultation procedure clarifies in advance whether, from a medical point of view, anything speaks against psychotherapy.
The notification procedure informs the health insurance fund that acute treatment is to begin — before it begins. Nothing more.
The application procedure leads to the determination of the health insurance fund’s obligation to pay.
The expert review procedure involves a specially qualified, appointed reviewer — and only in certain cases.
The consultation report comes first
First, as to who is concerned: the provision is addressed to psychological psychotherapists, to child and adolescent psychotherapists and to specialist psychotherapists (Fachpsychotherapeuten). For medical psychotherapists, the somatic clarification is regulated differently.
The referral must take place at the latest after the end of the probationary sessions and before the start of therapy under the Directive. The words at the latest matter: earlier is possible too, and anyone who knows the waiting times prefers to obtain the report early.
It is drawn up after a personal examination and must be transmitted at the latest three weeks after this examination. Its content is laid down in nine points: current complaints, mental and somatic findings, relevant anamnestic data, any necessary psychiatric clarification, previous and parallel treatments including current medication, diagnoses including differential and suspected diagnoses, findings for accompanying medical treatment, further examinations required and any contraindications.
One point in it has consequences: if the consulting physician considers psychotherapy to be contraindicated and an application is nevertheless made, the health insurance fund arranges for an assessment by the Medical Service (Medizinischer Dienst).
Notify, apply, review
Acute treatment is only notified. Before it begins, the health insurance fund is informed of the diagnosis and the date on which treatment begins. Its price lies elsewhere: if therapy under the Directive follows, the units provided are counted towards the allowance — the Directive expressly names short-term therapy 1 for this.
Short-term therapy is applied for, in two steps of up to twelve therapy units each. A subtlety that determines the schedule: KZT 2 can be applied for at the earliest after seven therapy units of KZT 1 have been delivered.
Long-term therapy is applied for — and approved short-term allowances are counted towards its allowance.
When an expert review really takes place
A shorthand persists here that is too coarse: “Long-term therapy means an expert review.”
What is correct: the regular obligation of an expert review requires two things at once. It must be an application for long-term therapy — and for individual therapy or for a combination of individual and group therapy that takes place predominantly as individual therapy.
Both of the following result from this: long-term therapy as pure group therapy or as a predominantly group-therapeutic combination is not subject to an expert review merely by virtue of its setting. And short-term therapy, as a rule, is not either. In both cases, however, the health insurance fund can request an expert review in the individual case — and it can in principle do so for any application it considers in need of examination.
One exception belongs here because it is regularly overlooked: if, after therapy under the Directive has ended, short-term therapy is applied for again, this application too must be submitted to the reviewer — unless more than two years lie between the end and the new application.
The deadline that is no longer in the Directive
And now the point at which reading only one of the two sources takes its revenge.
Until the amendment in June 2026, the Psychotherapy Directive named a fixed number of sessions for the conversion of short-term therapy into long-term therapy. The current version no longer does so; it only requires that the application be made in good time and in such a way that treatment can be continued without interruption.
Anyone who concludes from this that there is no longer a deadline is mistaken. The Psychotherapy Agreement, which continues to apply, specifies unchanged:
If it becomes apparent during short-term therapy that long-term therapy has to be carried out, the transfer of short-term therapy into long-term therapy must be applied for at the latest with the eighth therapy unit of KZT 2.
— Psychotherapy Agreement, § 11 paragraph 5 sentence 4 (our translation)
With KZT 1 fully used up, this arithmetically corresponds to twenty therapy units — the number many have in mind. What is decisive today, however, is no longer an absolute number of twenty sessions, but the eighth therapy unit of KZT 2. The earlier version of the Directive expressly named the twentieth session; today, twenty is only the result of a calculation, and one that turns out differently if KZT 1 has not been fully used up.
Here too: if the conversion application is for individual therapy or for a predominantly individual-therapeutic combination, the health insurance fund submits it to a reviewer.
What goes into the report
If an application for long-term therapy subject to expert review is made or short-term therapy is to be converted into long-term therapy, this application should also contain a case-related treatment plan — the report to the reviewer: diagnosis as well as the type and scope of the planned psychotherapy, the justification of the indication, information on the mental and somatic findings, treatment-relevant information on the life history, the method-specific model of the disorder, information on frequency and prognosis — and on relapse prevention.
That is the Directive. For the practical submission, the Psychotherapy Agreement goes further, and without the restriction to applications subject to expert review: every application for long-term therapy and every conversion application must be accompanied, in addition to form PTV 2, by a sealed envelope for the reviewer — PTV 8, with the report, the copy of PTV 2, the copy of the consultation report where required, and supplementary findings reports where required.
And one sentence that counts in its own right: the report must be written entirely and personally by the psychotherapist (§ 11 paragraph 6 sentence 3 of the Agreement).
For the continuation application, a condition applies that is easily overlooked: only if a reviewer is commissioned with the examination must the course and result of the treatment so far be set out and a reasoned prognosis given. A continuation application therefore does not automatically entail a detailed report — first, the health insurance fund decides whether to have an expert review carried out.
This is at the same time an answer to why ongoing documentation of the course of treatment saves work: if there is an expert review, one writes from existing material. If there is none, nothing has been lost.
Who reviews — and under which conditions
The expert review procedure is initiated by the health insurance fund. It selects from the appointed reviewers; a sufficient geographical distance from the practice submitting the application should be taken into account.
Reviewers are appointed by the National Association of Statutory Health Insurance Physicians in agreement with the GKV-Spitzenverband. They are themselves specialist physicians or psychotherapists with completed further training or proof of specialist expertise in the respective method — so the review takes place within the method, not across methods —, and several years of current care activity as well as several years of recent supervision activity are required.
One reservation belongs here: for reviewers with an appointment that already exists and is valid until 31 December 2027, the previous qualification requirements remain unaffected until that date. The new criteria therefore do not yet apply across the board.
What is examined is whether the conditions laid down in the Directive and the Agreement are met: whether the method applied for is recognised and indicated in the specific case, whether the prognosis gives reason to expect sufficient treatment success, and whether the proposed scope of treatment is appropriate. An expert review is therefore not a second opinion on the therapy, but an examination against a fixed standard.
One requirement in this deserves particular attention: neither the practice nor the health insurance fund may provide the reviewer with any documents other than those on which the personal data of the insured person are pseudonymised. In the expert review procedure, pseudonymisation is therefore not good style, but mandatory.
The consultation report must be transmitted to the reviewer insofar as it is required at all.
Three weeks — twice, but not the same
This is the part worth remembering. In the application procedure there are two three-week rules, and they differ in strictness. (The third deadline of this length, mentioned further above, concerns the consultation report and does not belong here.)
First, for short-term therapy. The health insurance fund must decide at the latest by the end of three weeks after receipt of the application. If it cannot do so — for example because the application needs clarification or the facts are of above-average complexity —, it must notify this in writing in good time, with sufficient reasons and an appropriate new decision date.
If this notification is not given, a legal consequence takes effect that is expressly stated in the Directive:
If no such notification is given by the end of the period under sentence 4, or if the new decision date under sentence 5 passes without result, the service applied for is deemed to be approved for provision by psychotherapists within the meaning of this Directive; this does not apply to services that cannot be provided at the expense of the health insurance funds under this Directive.
— § 34 paragraph 1 sentence 6 PT-RL (our translation)
The rules of § 13 paragraph 3a SGB V (German Social Code, Book V) remain unaffected alongside. And this is a legal consequence, not a course of action: one does not bring it about, one knows it.
Second, for the continuation application. If the health insurance fund does not initiate an expert review procedure, it must approve the continuation application within three weeks of receipt, provided the formal conditions are met. This rule does not, however, contain an expressly worded deemed approval as for short-term therapy.
At the other end there is a protective rule with a subtle but important difference: if the insured person lodges an objection against the refusal of short-term therapy, the fund can obtain an expert opinion. For long-term therapy, on the other hand, it must obtain such an opinion before refusing — provided the formal conditions are met.
Four questions with which a case can be classified
First: acute treatment or therapy under the Directive? Acute treatment is notified, not applied for — and its units are counted later.
Second: short-term or long-term therapy, and in which setting? For the regular obligation of an expert review, it is the combination that matters: long-term therapy in an individual setting or as a predominantly individual-therapeutic combined treatment.
Third: first application, conversion or continuation? The conversion must be applied for at the latest with the eighth therapy unit of KZT 2 — earlier is permissible. For the continuation application, the fund first decides whether there will be an expert review at all.
Fourth: when exactly was the application received? Both three-week rules of the application procedure just mentioned run from receipt of the application. Anyone who does not record the date cannot say later whether the deadline has passed.
The fourth question is the most inconspicuous and the only one that can be settled entirely by oneself: it costs one note.
What is changing right now
Since June 2026, the Psychotherapy Directive has created the basis for digitising the notification, application and expert review procedures, which have so far been paper-based.
How the digital procedure will be designed and from when it can be used must, however, first be regulated by the National Association of Statutory Health Insurance Physicians and the GKV-Spitzenverband in the Psychotherapy Agreement. The new § 39 paragraph 3 of the Directive expressly assigns to them the task of regulating the details of implementation, including digitisation. The resolution opens up the scope — it does not introduce the procedure.
About the status of this text
The information is taken from the Psychotherapy Directive in the version of 19 February 2009, last amended on 19 March 2026, in force since 17 June 2026, and from the Psychotherapy Agreement, Annex 1 to the Federal Collective Agreement for Physicians (BMV-Ä), of 1 January 2025.
The approval steps and maximum limits are deliberately not reproduced. The Directive distinguishes ten constellations there by method and age group; a selection from them in running text is the most likely source of wrong numbers. Anyone who needs them will find them in § 30 — and should read them there, not here.
This article reflects the status as of 27 August 2026. It offers orientation, not legal advice, and does not assess any specific application. Because the Directive version in force is only a few weeks old and the implementation of digitisation is still pending, we review this text quarterly. This is a translation; the German version („Wer prüft was“) is authoritative.
A note on our own behalf: this text comes from Psymira, a provider of documentation software for psychotherapy practices. Two points touch our subject directly — the documentation of the course of treatment for continuation applications and the mandatory pseudonymisation of documents in the expert review procedure. The application is made by the insured person; the professional justification and the report are the responsibility of the treating psychotherapist. For the report, the requirement of the Psychotherapy Agreement additionally applies that it must be written entirely and personally.