Mental health professionals rely on various forms of documentation to track client progress, maintain treatment plans, and ensure effective care. Among these, progress notes and psychotherapy notes serve distinct purposes in clinical practice. While both are essential for recording client interactions, they differ in terms of content, usage, legal protections, and accessibility.
This article provides a detailed comparison of progress notes vs. psychotherapy notes, outlining their functions, significance, and implications for mental health practitioners and clients alike.
What Are Progress Notes?
Definition and Purpose
A progress note is a formal, structured document that records essential details about a client’s treatment session. These notes are primarily used for clinical continuity, treatment planning, and insurance documentation. Progress notes are part of the client’s official medical record, meaning they can be accessed by other healthcare providers, billing departments, and sometimes even insurance companies.
Key Elements of a Progress Note
A well-written progress note typically includes:
- Session Date and Time – Documenting when the session took place
- Client Presentation – Observations about the client’s mood, affect, and general mental state
- Interventions Used – Techniques, strategies, or therapeutic modalities applied during the session
- Client Response – How the client reacted to the interventions or any progress made
- Treatment Plan Updates – Any changes or adjustments in goals, interventions, or medication recommendations
- Next Steps – Plans for the next session, homework assignments, or referrals
A common structure used for progress notes is the SOAP format:
- S (Subjective): The client’s self-reported thoughts, feelings, and concerns
- O (Objective): Therapist’s observations, including mood, behavior, and speech
- A (Assessment): Clinical interpretation of the client’s current state and progress
- P (Plan): Next steps, goals, or modifications to treatment

Who Can Access Progress Notes?
Since progress notes are part of the official medical record, they can be accessed by:
- Other healthcare providers involved in the client’s treatment
- Insurance companies (for billing and reimbursement)
- Legal entities if required by law (e.g., court subpoenas)
- Clients, in most cases, if they request a copy of their records
Because progress notes are subject to HIPAA regulations in the U.S. and similar privacy laws worldwide, therapists must ensure they are professional, factual, and clinically relevant while avoiding unnecessary personal details.
What Are Psychotherapy Notes?
Definition and Purpose
A psychotherapy note is a private document created by a therapist to capture personal reflections, hypotheses, or deeper insights into a client’s therapy process. Unlike progress notes, psychotherapy notes are meant for the therapist’s use only and are not part of the official medical record.
These notes help therapists track themes, emotional patterns, transference issues, and treatment ideas without being bound by the structured format required in progress notes.
Key Elements of a Psychotherapy Note
Psychotherapy notes may include:
- Detailed personal reflections about the session
- Hypotheses about client behavior or emotions
- Therapist’s thoughts on future interventions
- Speculations on unconscious patterns or relational dynamics
- Personal countertransference reflections (how the therapist feels in response to the client)
Unlike progress notes, psychotherapy notes do not contain:
- Specific treatment details like diagnosis, medication, or clinical interventions
- Information required for billing or insurance purposes
- Objective descriptions of client symptoms
Who Can Access Psychotherapy Notes?
Psychotherapy notes are protected under HIPAA privacy laws and are not shared with clients, insurance companies, or other providers. The only exceptions might be legal cases where a court orders access, but even then, extra legal steps are required.
Because these notes are confidential, therapists should store them separately from progress notes to avoid accidental disclosure.
Key Differences Between Progress Notes and Psychotherapy Notes
| Feature | Progress Notes | Psychotherapy Notes |
| Purpose | Clinical documentation, insurance billing, treatment continuity | Personal reflections, deeper insights into therapy sessions |
| Content | Objective session details, interventions, client response | Subjective thoughts, interpretations, patterns, transference |
| Format | Structured (SOAP, DAP, BIRP, etc.) | Unstructured, informal |
| Storage | Part of the official medical record | Kept separately for therapist’s use |
| Access | Available to healthcare providers, insurance companies, and clients (in most cases) | Strictly private and not shared without therapist’s consent |
| Legal Protection | Subject to HIPAA and legal requests | Extra legal protections under HIPAA |
Why These Differences Matter
Understanding the distinction between progress and psychotherapy notes is important for both therapists and clients:
- For Therapists:
- Helps maintain legal and ethical standards in documentation
- Ensures clear, factual records for clinical and billing purposes
- Provides a separate space for personal insights that may influence treatment
- For Clients:
- Ensures transparency in medical records while maintaining privacy for sensitive discussions
- Helps navigate insurance claims and understand what is being documented
- Provides assurance that deeper, more personal reflections are not shared in official records
Final Thoughts: Which One Is More Important?
Both progress notes and psychotherapy notes serve vital but distinct roles in mental health care. Progress notes are essential for clinical, legal, and insurance purposes, while psychotherapy notes allow therapists to process deeper insights privately.
Mental health professionals should ensure they clearly separate these two types of notes to maintain client confidentiality and uphold ethical documentation practices. Likewise, clients should be aware of their rights regarding access to their records and how their information is being stored and used.
By understanding these differences, both therapists and clients can foster a more transparent, effective, and ethically sound therapeutic relationship.