Psychological interventions have shown efficacy for the treatment of different psychological problems. Now, we need to know what processes make these results possible. The observational analysis of the verbal interaction of the therapist and the client has been used to analyze the learning processes that underlie the change in the client's behavior. However, previous coding systems have conceptual and methodological limitations. Therefore, the purpose of this article is to develop a functional coding system for the analysis of verbal interaction in clinical contexts. To this end, we developed and debugged a new functional description-based system. Also, we have analyzed 66 clinical sessions belonging to 23 different cases using the new coding system and the results have been compared with previous studies. The main result of this study is a system consisting of 5 functional categories with good reliability indices and methodological properties. The discriminant and cluster analysis have yielded similar results to those of previous studies. Finally, we discuss about conceptual and methodological advances of this new system, we list the main limitations, and we propose further studies in this line of research.