I often have therapists tell me they are treating a current patient for a specific diagnosis/condition and that the patient will be returning to see their physician for a follow-up visit. The therapist tells me they wrote a Progress Report and sent it to the physician to provide the physician with the most current status of their patient. In order to write the Progress Report, the therapist not only gathered subjective comments from the patient and/or their family, but also gathered objective data, tests, and measures that included range of motion measurements and manual muscle testing. Since the therapist took these measurements and performed the manual muscle testing, they then ask me, can I bill CPT code 95831 – Muscle testing, manual (separate procedure) with report; extremity (excluding hand) or trunk and CPT code 95851 – Range of motion measurements and report (separate procedure); each extremity (excluding hand) or each trunk section (spine) and my answer without asking them another question is no and I’m usually right with this answer 99% of the time.
Why am I right? Because in order to bill CPT codes 95831 and 95851, the therapist must perform manual muscle testing and take range of motion measurements of
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