So, as said, in the US it's your technical right to get your records. And therapists can refuse. There's no real uniformity - from what I have learned, it all depends on the type of therapist (LPC, LSW, Pdoc, ect) and if they have a private practice versus an office with many workers. More workers = better chance.

If it's the money part, there might be creative ways around it. You can try to get it through another professional - sign a release of info on your records and see if the therapist delivers. Nothing can be done if they don't. You can try a pro bono lawyer, who can subpena your records, but you must have an active case from what I understand. I have heard of people trying to beat an abusive therapist at their own game. One convinced exT that she wanted to burn all records in a ceremony of closure - and he handed it all over. I'm not saying I encourage deception, just letting you know what I have learned in my own search on the same topic.

It's really an area that is so under-regulated and ought to be easier.