My T has never taken one note during session-- and he doesn't do insurance either... yet somehow he has a big file on me, lol. I know this because I have to sign for each session... and the signature paper is attached to the file. The only time I saw him refer to his notes was 2 weeks ago when I gave him 'homework' to remind me of exactly what we were talking about at the end of the previous session. He looked into the notes and told me-- I was teasing him about that. I'm sure he writes them after I leave; all Ts do.

Notes are necessary... especially for malpractice... although your T doesn't go through health insurance, he definitely has liability insurance for himself... he would definitely need to keep notes on clients should anything ever happen... I'm sure they also need to write down some detail and perphaps review them sometime before the session. I know that in general, my T is an extraordinary listener, and remembers things that I am pretty sure are not in his notes... I mean, he has brought up specifics of dreams that I have told him about, weeks after the conversation... stuff that I don't even remember! However, I still think he keeps notes to review progression/regression trends in our work together.