Free Therapist Training›Psychodynamic Therapy Toolkit›Psychotherapy Process Notes
Last updated: November 11, 2026
Process notes are a detailed record of part of a therapy session: what the client said, what the therapist said, and what the therapist was thinking and feeling at each turn. Written for supervision, they show a supervisor the moment-to-moment work that a progress note leaves out. The template below has four parts, and a completed example for an invented client follows. Below the example, the guide explains how process notes differ from progress notes and from the legal category of psychotherapy notes under HIPAA, and what California law adds.
The template is part of the Sentio MFT program's free psychodynamic therapy toolkit. The progress note for the same session is on the progress note page.
This is an optional aid from the Sentio MFT program's psychodynamic therapy toolkit. It is not an official form of any agency or payer.
Download the PDFMake an editable copy
Part 1. Session details
| Item | Entry |
|---|---|
| Client code (no name) and session number | |
| Date written | |
| What came just before this excerpt | |
| Why I chose this excerpt |
Part 2. The exchange
| Line | What was said, as close to word for word as I can recall | What I was thinking and feeling | Supervisor's comments |
|---|---|---|---|
| C1 | |||
| T1 | |||
| C2 | |||
| T2 | |||
| C3 | |||
| T3 |
Part 3. Reflection
- What pattern did I see, in the client and between us?
- What did I feel, and what did I do with it?
- What did I avoid or miss?
- What would I say now, given another chance?
- My question for supervision.
Part 4. Keeping it
- Use a client code, not a name, and leave out details that could identify the client.
- Keep process notes apart from the client's record, and follow your site's policy on who may see them and how long they are kept.
What Do Completed Process Notes Look Like?
The example records about eight minutes of session 6 with Elena, an invented client in weekly treatment for depression, written by her therapist for supervision. The supervisor's comments were added in supervision. Below it, the same minutes appear as they do in the progress note, so you can see one session written both ways.
Part 1. Session details
| Item | Entry |
|---|---|
| Client code (no name) and session number | E-14, session 6 |
| Date written | The evening after the session |
| What came just before this excerpt | About 20 minutes in. She had described agreeing, at Monday's department meeting, to join another committee. |
| Why I chose this excerpt | The first time she cried in session, and the first time she named her pattern with me. |
Part 2. The exchange
| Line | What was said | What I was thinking and feeling | Supervisor's comments |
|---|---|---|---|
| C1 | "So I said sure, I'd take it. And I offered to do the minutes, because nobody else ever does them." (Even voice.) | The same even tone. I am already composing advice about saying no. That is my pull to fix things for her. | |
| T1 | "Can we slow down at the moment she asked? What happened inside you right before you said 'sure'?" | Choosing inquiry instead of advice. | Good: a specific moment, not a general question. |
| C2 | "I don't know. My throat got tight, I guess." (Pause.) | Something is there. | |
| T2 | "Your throat got tight. Can you stay with that for a moment, with what the tightness is about?" | Slowing down. I feel nervous she will shut it off. | |
| C3 | (Eyes fill.) "I just wanted someone to ask if I had room." (Laughs, wipes her eyes.) "Anyway. It's fine. It's just a committee." | A wave of sadness in me, then relief when she laughed. I felt let off the hook, and I noticed that. | |
| T3 | "I notice that just as the sadness came, we both moved on to 'it's fine.' What do you think would happen if we stayed with it a moment longer?" | I said "we" because I felt the relief too. Was that too much? | Not too much. Owning your part of the move makes the comment an invitation rather than a correction. |
| C4 | "I don't want to waste our time on this. You probably see people with real problems." | There it is, with me. | |
| T4 | "So part of you expects that if you bring me something that matters to you, I'll feel it's a waste. Maybe the way you expected your chair would see you if you said no, and the way it felt with your mom, that your needs would weigh on her." | Long. I stacked three links into one statement. | It landed, but three links at once is a lot. Next time, offer the link with you alone and let her find the others. |
| C5 | (Quiet.) "That's... yes. I do that everywhere." (Cries more openly.) | Moved. Also aware of wanting this to be a breakthrough. | |
| T5 | "You do. And right now you're doing something different, letting me see it." | Was that praise? I want to mark the new experience without making her perform it for me. | Worth watching. If she starts bringing tears to please you, the pattern has found a new form. |
Part 3. Reflection
- Pattern: She hid the wish to be asked whether she had room and covered the sadness with "it's fine." With me, she expected I would find her problem small.
- What I felt and did: A pull to give advice, relief when she minimized, and a wish to turn the moment into a success. I named the shared relief instead of acting on it.
- What I avoided: The anger in "nobody else ever does them." I let it pass.
- What I would say now: "'Nobody else ever does them.' There's some feeling in that, too."
- My question for supervision: How do I make room for her anger without her hearing it as criticism?
Part 4. Keeping it: Written under the client code, with no identifying details, kept in a locked file apart from the chart, and shared only with my site supervisor under the site's policy for process notes.
The Same Session as a Progress Note
The progress note for session 6 records the same minutes in two rows of the clinical record:
| Progress note item | Entry for session 6 |
|---|---|
| Interventions | Explored the department meeting step by step, including what she wanted and expected (therapeutic inquiry). Invited her to stay with the tightness in her throat and the sadness that followed (deepening emotional experience). Named the move to "it's fine" as a way of leaving the sadness and explored what it protects her from (working with defenses). Commented on her worry that she was wasting the session (process comment) and tentatively linked it to her expectations at work and with her mother (transference interpretation). Asked what she imagines would have happened had she declined the committee (exploring fantasy). |
| Client response | Tearful when she said she wanted to be asked "if I had room." Laughed and minimized, then returned to the feeling when invited. Agreed that she expected the therapist to find her problems small and said, "I do that everywhere." Imagined the chair's face "going cold," and also imagined the chair saying, "Of course, I didn't realize." |
The process note keeps what the record leaves out: the exact words, the therapist's relief when the client laughed, the pull to give advice and the supervisor's comments. The progress note keeps what the record needs: what was done, how the client responded and what comes next.
What Are Process Notes?
Process notes reconstruct a stretch of a session, line by line, with the therapist's inner responses beside each exchange. They show a supervisor what a summary cannot: the timing of an intervention, the feeling that preceded a change of subject, the moment the therapist was pulled into the client's pattern. Writing them is itself a discipline, because recalling the exchange makes the therapist notice what was felt and avoided. They are used in psychodynamic supervision, and they remain a direct way to learn to hear transference and countertransference.
Recordings, with the client's written consent, now do some of the same work, and the toolkit's recording review form is built for that. Process notes still add something a recording cannot: the therapist's own account of what was going on inside.
Psychotherapy Notes vs. Process Notes vs. Progress Notes: What Is the Difference?
The three terms overlap, and only one of them is defined in law. Progress notes are the record of care. Process notes are a training document. Psychotherapy notes are a category in the HIPAA Privacy Rule, defined in 45 CFR 164.501 as notes recorded by a health care provider who is a mental health professional, documenting or analyzing the contents of conversation during a private, group, joint or family counseling session, kept separate from the rest of the individual's medical record. The definition excludes medication prescription and monitoring, session start and stop times, the modalities and frequencies of treatment, clinical test results, and any summary of diagnosis, functional status, the treatment plan, symptoms, prognosis and progress to date. The federal Department of Health and Human Services adds that psychotherapy notes do not include any information maintained in the client's medical record.
| Progress notes | Process notes | Psychotherapy notes (HIPAA) | |
|---|---|---|---|
| What it is | The record of care for each session | A training term, not a legal one: a detailed account of an exchange with the therapist's reactions beside it | A legal category defined in 45 CFR 164.501 |
| Main purpose | Documenting treatment for the clinical record, other providers and payers | Learning and supervision | The clinician's own notes analyzing session conversation |
| Where it is kept | In the client's record | Usually apart from the record, under the training site's policy | Separated from the rest of the medical record, by definition |
| Typical content | Focus, observations, risk, interventions, response, progress, plan | Near-verbatim dialogue, the therapist's thoughts and feelings, questions for supervision | Contents of conversation and the clinician's analysis; never medication, session times, modality and frequency of treatment, test results or summaries of diagnosis, functional status, plan, symptoms, prognosis or progress |
| Client access under HIPAA | Generally yes, as part of the designated record set | Depends on how they are kept: kept apart, they can meet the definition of psychotherapy notes; filed in the record, they are part of it | Excepted from the right of access (45 CFR 164.524(a)(1)(i)) |
HIPAA's privacy rules apply to covered entities and, for some requirements, to their business associates. A health care provider is a covered entity only if it transmits health information electronically in connection with a standard transaction, such as an insurance claim (45 CFR 160.103). Our guide to whether HIPAA applies to a California therapy practice explains that test.
When Do Process Notes Count as Psychotherapy Notes?
When they meet the definition. A process note written by a mental health professional, analyzing the conversation of a session and kept apart from the client's record, fits the federal definition of psychotherapy notes. The same note filed in the chart, or copied into the progress note, does not, because psychotherapy notes exclude information kept in the medical record.
For a covered entity, the category carries three protections. Most uses and disclosures need the client's written authorization (45 CFR 164.508(a)(2)). The exceptions include use by the clinician who wrote the notes for treatment, use or disclosure in the covered entity's own training programs in which students, trainees or practitioners in mental health learn, under supervision, to practice or improve their counseling skills, the entity's defense in a legal action or other proceeding brought by the client, and a few others: disclosures to the Department of Health and Human Services to check compliance, disclosures required by law, health oversight of the clinician who wrote the notes, disclosures to coroners and medical examiners, and disclosures to prevent or lessen a serious and imminent threat to health or safety. An authorization for psychotherapy notes may be combined only with another authorization for psychotherapy notes (45 CFR 164.508(b)(3)(ii)). And psychotherapy notes are excepted from the client's right of access (45 CFR 164.524(a)(1)(i)), a ground for denial that is not subject to review (45 CFR 164.524(a)(2)(i)). The Department of Health and Human Services notes that a provider may still choose to share psychotherapy notes with the client, subject to state law.
For trainees, the training exception matters most. A process note shared with a supervisor inside the covered entity's own training program falls within it. When a process note leaves that setting, for a class or an outside consultant, remove the details that could identify the client, or obtain the client's written authorization.
What Does California Law Add?
Supervision includes process notes. California's law for marriage and family therapists defines supervision to include reviewing the supervisee's progress notes, process notes and other patient treatment records, as the supervisor deems appropriate, and monitoring and addressing clinical dynamics, including countertransference-related issues that may affect the supervisory or the practitioner-patient relationship (BPC 4980.43.1(b)).
The Confidentiality of Medical Information Act applies whether or not HIPAA does. It binds providers licensed under Division 2 of the Business and Professions Code, bars disclosure of medical information without an authorization except in the circumstances it lists, and requires records to be kept and disposed of in a way that preserves confidentiality (Civil Code sections 56.05, 56.10 and 56.101). Our HIPAA and California records guide covers the Act in detail.
California's patient access law defines patient records broadly. The law covers licensed marriage and family therapists, clinical social workers and professional clinical counselors, among other providers (Health and Safety Code section 123105(a)). Patients may inspect their patient records within five working days after the provider receives their request, and receive copies within 15 days (Health and Safety Code section 123110). "Patient records" means records in any form or medium maintained by, or in the custody or control of, a health care provider, relating to the patient's health history, diagnosis or condition or to treatment provided or proposed, and the definition does not set psychotherapy notes apart (section 123105(d)). A provider who determines that seeing mental health records poses a substantial risk of significant adverse or detrimental consequences to the patient may decline the request, but must record the reason, tell the patient, and allow inspection by, or copies to, a licensed physician, psychologist, marriage and family therapist, clinical social worker or professional clinical counselor whom the patient designates (section 123115(b)).
HIPAA does not override greater state access rights. A state law that gives individuals greater rights of access is "more stringent" under HIPAA and is not preempted (45 CFR 160.202 and 160.203(b)). In California, then, the HIPAA exception for psychotherapy notes may not by itself settle a patient's request to see process notes. A specific request is worth taking to counsel, and our guide to minor consent and parent access to therapy records in California covers requests from parents.
How Should You Keep Process Notes?
- Write under a client code and leave out details that could identify the client.
- Keep process notes apart from the client's record, never in a shared field of the electronic record.
- Keep verbatim material out of the progress note; summarize instead.
- Follow your site's written policy on who may read process notes, where they are stored and how long they are kept, and ask for that policy if you have not seen it.
- Bring them to supervision promptly, while the session is fresh enough to be useful.
Keep reading
Psychodynamic Progress Note Template, the progress note for the same session, in narrative and SOAP versions
Does HIPAA Apply to Your California Therapy Practice?, covered entities, the Confidentiality of Medical Information Act and records retention
Minor Consent and Parent Access to Therapy Records in California, when parents can see a minor client's records
Clinical Supervision Notes Template, the supervisor's record of reviewing progress and process notes
Frequently Asked Questions
What is the difference between process notes and progress notes?
Progress notes are the record of care: what the session addressed, what the clinician did, the client's response, risk, progress and the plan. Process notes are a training document that reconstructs part of a session nearly word for word, with the therapist's thoughts and feelings, for supervision.
Are process notes the same as psychotherapy notes?
Not automatically. "Psychotherapy notes" is a HIPAA category: notes by a mental health professional analyzing session conversation and kept separate from the medical record. A process note kept apart from the record can meet that definition; a process note filed in the chart is part of the record.
Do clients have a right to see process notes?
Under HIPAA, psychotherapy notes kept separately are excepted from the client's right of access, though a provider may choose to share them. In California, the patient access law defines patient records broadly, and HIPAA does not override state laws that give patients more access, so a specific request is worth taking to counsel.
Can I share process notes with my supervisor?
HIPAA lets a covered entity use psychotherapy notes without the client's authorization in its own mental health training programs, where students, trainees or practitioners learn under supervision, and California's definition of supervision for marriage and family therapists includes reviewing process notes. Remove identifying details when notes leave the setting where the client is seen.
Should process notes include my own feelings?
Yes. The therapist's thoughts and feelings beside each exchange are what make process notes useful in supervision, especially for noticing countertransference.
References
Access of individuals to protected health information, 45 C.F.R. § 164.524. https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-E/section-164.524
California Business and Professions Code § 4980.43.1. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC§ionNum=4980.43.1
California Civil Code § 56.05. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CIV§ionNum=56.05
California Civil Code § 56.10. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CIV§ionNum=56.10
California Civil Code § 56.101. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CIV§ionNum=56.101
California Health and Safety Code § 123105. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC§ionNum=123105
California Health and Safety Code § 123110. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC§ionNum=123110
California Health and Safety Code § 123115. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC§ionNum=123115
Definitions, 45 C.F.R. § 160.103. https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-160/subpart-A/section-160.103
Definitions, 45 C.F.R. § 160.202. https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-160/subpart-B/section-160.202
Definitions, 45 C.F.R. § 164.501. https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-E/section-164.501
General rule and exceptions, 45 C.F.R. § 160.203. https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-160/subpart-B/section-160.203
U.S. Department of Health and Human Services. (n.d.). Does a parent have a right to receive a copy of psychotherapy notes about a child's mental health treatment? Retrieved November 9, 2026, from https://www.hhs.gov/hipaa/for-professionals/faq/does-parent-have-right-receive-copy-psychotherapy-notes-about-childs-mental-health-treatment.html
U.S. Department of Health and Human Services. (n.d.). Does HIPAA provide extra protections for mental health information compared with other health information? Retrieved November 9, 2026, from https://www.hhs.gov/hipaa/for-professionals/faq/2088/does-hipaa-provide-extra-protections-mental-health-information-compared-other-health.html
U.S. Department of Health and Human Services. (n.d.). What personal health information do individuals have a right under HIPAA to access from their health care providers and health plans? Retrieved November 9, 2026, from https://www.hhs.gov/hipaa/for-professionals/faq/what-personal-health-information-do-individuals/index.html
Uses and disclosures for which an authorization is required, 45 C.F.R. § 164.508. https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-E/section-164.508
