EHR for LCDCs in Texas: what the rules ask and what to look for

Where you work decides which rules apply

The LCDC rules moved from 25 TAC chapter 140 to 26 TAC chapter 562, effective January 31, 2025, per the Texas Register transfer notice. Section 562.24 sets the standards for an LCDC's private practice. Records you write inside another setting follow that setting's documentation rules. That split matters when you pick software:

Where you work	Whose records rules	Who picks the EHR	Cima plan that fits
Your own private practice	26 TAC §562.24, plus HIPAA, Part 2 and Texas privacy law	You	Solo, $59 a month
A group practice with other clinicians	Each license's own rules; the practice's policies	The owner	Solo plus $39 per added clinician (group practices)
A licensed chemical dependency treatment facility (OP, IOP, PHP)	26 TAC chapter 564, see our 26 TAC 564 guide	The facility	Program, $399 a month for up to 25 clients (Cima for IOP and PHP)
Both: a job at a program and a few private clients	Two sets of records, never mixed	The facility for its clients; you for yours	Solo for your own clients only

Whether an LCDC can open a private practice at all, and what it can bill, is its own question. Our guide to an LCDC private practice in Texas covers the license exemption, the scope limits and the payers.

The 26 TAC 562.24 record, line by line

Here is what §562.24 asks of a private practice record, and where each item lives in Cima. The rule's own wording is on the Cornell LII copy of 562.24; check the current text with the HHSC LCDC program before you write your policy.

What 562.24 asks	Where it is in Cima
A record for each client, opened at the first service, with identifying information	The client's details: name, date of birth, sex at birth (Texas now requires it), contact, emergency contact, insurance and chart number. A booking from your online page starts the chart.
Assessment results and diagnosis	The intake assessment note (presenting problem in the client's words, history, substance use, psychiatric and medical history, family, social, work and legal, mental status, risk, diagnostic impression), and the ICD-10 diagnosis list on the chart. A claim can only point at a diagnosis on that list.
A plan of care	The treatment plan form: problems in the client's words, goals, measurable objectives with target dates, interventions, frequency, a review-by date, and whether the client took part and agrees. Progress notes ask what progress was made toward the plan's goals.
A log of services	Every visit and signed note on the chart with its date, start and end time, author and billing code.
The client's status when services end	The discharge summary: reason (goals met, chose to stop, stopped attending, referred to a higher level of care, moved), course of treatment, status at discharge, recommendations and referrals.
Charges and payments	Signing a billable note creates the charge. Insurance payments post from the payer's electronic remittance and client payments are recorded on the ledger, with statements and superbills.
Entries durable, legible, accurate, timely, dated and authenticated	You sign with your PIN. The signature records your name, credential and license number, the server's time and a fingerprint (hash) of the exact text signed. A note signed more than 72 hours after the session is marked LATE ENTRY on the note itself; nothing can be backdated.
Errors corrected without erasing (single line, dated, initialed)	That's the paper method. In Cima a signed note can't be edited or deleted; the database refuses it. You write a dated, signed addendum, and the original stays readable under it. Ask HHSC if you want its view on electronic corrections.
Records protected from loss, tampering and unauthorized access; electronic records backed up	Encryption, sign-in with a passkey, Google or Microsoft, or a password plus an authenticator code, every chart view logged, each practice in its own database, and nightly encrypted backups kept 6 years. How Cima protects records.

Retention. We couldn't confirm a retention period in the LCDC rules as of this update; our Texas records retention guide uses the counselor board's 7 years as a floor for individual LCDCs and says to confirm with HHSC. Cima shows each discharged chart's keep-until date as 7 years from discharge, or age 25 for a client who was a minor, whichever is later, and a legal hold stops it from ever reading as destroyable. Cima never destroys a chart on its own.

Counselor interns and co-signs

A counselor intern works under a qualified credentialed counselor's supervision. In a licensed facility, 26 TAC 564 defines who counts as a QCC, and our 26 TAC 564 guide covers the co-sign rules there. In Cima:

• Credential decides the path. A note signed by a user whose credential is CI, LCDC-I, LPC-A, LMFT-A, intern, tech or peer goes to "awaiting co-sign" instead of final. An unrecognized credential also waits for a co-sign; Cima fails safe.
• The supervisor sees it on their To sign list, can open that note even for a client who isn't on their caseload, and co-signs with their own PIN. The record says "Reviewed and co-signed by" with their name and credential.
• Or sends it back with a comment. The comment becomes part of the note's history, the intern fixes the draft and signs again, and both signatures stay on the record.
• An LCDC, LPC, LCSW, LMSW, LMFT, psychologist, physician, NP or PA signs alone.

Billing codes: H0001, H0004, H0005 and CPT

Plans that pay LCDCs for substance use counseling often use HCPCS codes, while others pay only CPT psychotherapy codes and only to master's-level clinicians. Ask each plan which codes it pays an LCDC for before you bill; our LCDC credentialing guide has the questions to ask. What Cima does with each:

Code	What it is	In Cima
H0001	Alcohol and drug assessment	Pick it on the intake assessment note instead of the default 90791.
H0004	Behavioral health counseling, per 15 minutes	On the progress note. You enter the units (a 50-minute session at 15-minute units is usually 3; check the plan's rounding rule). Cima doesn't count H0004 units from the session length yet; it does pick 90832, 90834 or 90837 from the minutes.
H0005	Alcohol and drug group counseling by a clinician	Not built in. Group notes are on the Program plan, where groups count toward a PHP or IOP day billed per diem (H0015 for SUD IOP, S0201 or H0035 for PHP), not group by group.
90791, 90832–90837, 90846, 90847	Diagnostic evaluation; psychotherapy by time; family therapy	Built in, with the time bands checked: 16–37 minutes is 90832, 38–52 is 90834, 53 or more is 90837.
80305–80307	Presumptive drug screens	On the drug screen note: specimen, observed or not, result, and the follow-up you must write for an unexpected positive, invalid or refused screen before you can sign.

On the claim, Cima puts your NPI and the taxonomy you set; the addiction counselor taxonomy is 101YA0400X. Modifiers are free-typed per line (HO, HF or whatever the plan's contract names). Before a claim goes out, it's checked for the NPIs, member ID, diagnosis pointers, an authorization when the chart says one is required, and the filing limit, which Cima sets to 95 days for a Texas practice; the timely filing guide explains the 95-day rule and the payers that differ. Claims go out as 837P through the clearinghouse at about 30¢ each, with 20¢ for the electronic payment back. For the codes payers use at each level of care, see IOP and PHP billing codes.

42 CFR Part 2 releases

If you treat substance use disorders and are federally assisted, 42 CFR Part 2 governs those records; the elements a written consent must have are in §2.31. Our Part 2 guide explains the 2024 rule. In Cima:

1. Write the release from the chart's Privacy tab: who receives it (person and organization), what may be shared (attendance, diagnosis, plan and progress, drug screens, medications, discharge summary, or the whole record), why (coordinating care, insurance, court or probation at the client's request, an employer at the client's request, family involvement), and an end date no more than 5 years out.
2. The client signs on their phone through a paperwork link that lasts 7 days and asks for their date of birth first. The wording includes the revocation right, that treatment and payment don't depend on signing, and, for substance use records, the Part 2 limits on what the recipient may do with them.
3. Once written, the wording never changes; a change is a new release. A signed release becomes a consent on the chart, and "Client took it back" ends it.
4. Sending records checks the consent first. Each release of records is recorded with the required Part 2 notice to the recipient, and the client's accounting of disclosures prints on request. Releases ending within 30 days show on Today to renew.

The release wording is ours, written to the rule; have your attorney review it before real clients sign. Cima isn't a law firm.

Assessments, treatment plans and screens

• Notes that won't sign incomplete. Each note lists what's missing: a required field, too few words in a section, a diagnosis not on the chart, a code that doesn't fit the note or the minutes, a telehealth session without the client's consent and location.
• Risk on every note. A moderate or high risk rating requires the safety plan and what was done before you can sign.
• PHQ-9 and GAD-7 on the client's phone, scored, with an immediate alert on the PHQ-9 self-harm item and a required clinician note about it.
• On the Program plan: a biopsychosocial assessment with each substance, withdrawal and overdose history, past treatment and recovery, and ASAM dimensions 1 to 6 with a risk rating for each; treatment plan reviews with evidence and the client's own words; and continued-stay reviews prompted 5 days before an authorization's last day. Our SUD treatment plan guide shows what a reviewer looks for.

Telehealth sessions

When a session is by video or phone, the note asks for the client's verbal consent for that session, how you checked their identity, where they are and which state, and, for audio only, why video wasn't used. The location starts from the last telehealth session but is never pre-confirmed: you ask again. Place of service and modifier must match the note (10 or 02, with 95 for video or 93 for audio only), or Cima won't let you sign. Texas facility rules on services by electronic means are in our 26 TAC 564 guide. Cima has no built-in video; you use your own HIPAA-ready video service.

What Cima doesn't do for LCDCs yet

• No H0005 group billing session by session; groups are a Program plan feature billed per diem.
• No automatic H0004 unit count from minutes.
• No Columbia suicide screen (C-SSRS) built in; PHQ-9 and GAD-7 are.
• No built-in video, no lab orders live yet, and no detox, residential or sober living levels.
• No direct connection to TMHP's TexMedConnect portal; claims go through Cima's clearinghouse to payers that accept them electronically (search the payer in Cima to see). See our Texas behavioral health EHR guide for Medicaid.
• No admissions CRM; for verifying benefits before a first session, Quick VOB is separate.

What it costs

An example, not an average: a solo LCDC sending 60 insurance claims a month pays the $59 Solo plan plus 60 claims and their electronic payments at 30¢ + 20¢: $89.00 a month. A cash-pay practice pays $59. Add a clinician or a supervised intern for $39 a month each; billing and front-desk logins are free. No setup fee and no percentage of collections. Every line is on the pricing page.

Questions

What EHR do LCDCs use in Texas?

Inside a licensed program, whatever the facility uses. In private practice, any EHR that keeps the 26 TAC 562.24 record (assessment, plan of care, service log, discharge status, charges and payments, authenticated entries, protected and backed up), writes Part 2 releases, and bills the codes your plans pay. Cima's Solo plan is built for that; see Cima for addiction counselors.

Can an LCDC bill insurance in Texas?

Some plans credential LCDCs and pay HCPCS codes like H0001 and H0004; others pay only master's-level clinicians. Medicaid and Medicare have their own rules. Ask each plan before you see its members. Cima puts your NPI, taxonomy and credential on the claim; whether the plan pays is up to the plan.

Does a counselor intern's note need a co-sign in Cima?

Yes. A note signed by a CI or LCDC-I waits for a licensed supervisor's co-sign before it's final, and the supervisor can co-sign or send it back with a comment.

How long must an LCDC keep records in Texas?

We couldn't confirm a period in the LCDC rules as of October 2026. Licensed SUD facilities keep records at least 6 years (adolescents at least 5 years after age 18) under 26 TAC 564.508. For your own practice, use 7 years as a floor and confirm with HHSC. Details in how long to keep records in Texas.

Is Cima 42 CFR Part 2 compliant?

It's built for it: releases with the §2.31 elements, the Part 2 notice on records sent, a consent check before any release, disclosures recorded, and a Business Associate Agreement with qualified service organization terms. Your policies and your attorney's review of the wording are still yours.

Can I use AI to draft my notes?

If the practice turns it on. Drafts run on AWS under our BAA, you review and sign every one, and the signed note says it was drafted with AI and who reviewed it, as Texas now requires. A client can ask that AI not be used on their notes, and Cima then refuses to draft for that chart.

Sources

1. 26 TAC §562.24, Standards for Private Practice, and 26 TAC chapter 562, Licensed Chemical Dependency Counselors (Cornell LII). §562.24 · chapter 562
2. Texas Register, transfer of 25 TAC chapter 140 subchapter I to 26 TAC chapter 562, effective January 31, 2025. sos.texas.gov
3. Texas HHSC, Licensed Chemical Dependency Counselor Program.
4. 26 TAC §564.1, definitions including qualified credentialed counselor (Cornell LII). law.cornell.edu
5. eCFR, 42 CFR Part 2 and §2.31, consent requirements.
6. Cima EHR's note templates, codes, co-sign rules, releases and retention (alturaops server/solo/templates.ts, codes.ts, releases.ts, server/ehr/records.ts, rights.ts), and the prices on cimaehr.com/pricing.

General information, not legal or billing advice. Rules and plan policies change; confirm with HHSC and each plan. If something here is out of date, tell us.