When Can I Use CPT Codes 95831and 95851

March 6, 2015
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Rick Gawenda
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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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  1. When looking at the description of codes 95831, 95832, 95851, and 95852, I see nothing about the therapist having to perform that testing on EVERY joint of the extremity. Where did you get this clarification so that I can have it to show my boss?

    1. In the description, it states extremity or each extremity. You can also purchase and read CPT Assistants April 2003, February 2004, and May 2008 for additional information from the American Medical Association.

  2. These codes are typically reserved for impairment ratings and are not to be used in lieu of evaluation services. Code 97164 would be appropriate if you are performing an re-evaluation for a progress report.

    1. Actually, the re-evaluation is not to be billed for a Progress Report. A re-evaluation is only appropriate to bill when the criteria for a re-evaluation have been met. I recommend you read this article (http://gawendaseminars.com/2016/current-news-posts/reevaluations-vs-progress-reports-whats-the-difference/) as well as check out my FAQs on re-evaluations at http://gawendaseminars.com/faqs/re-evaluations/

      CPT codes 95831 and 95851 are not reserved for only impairment ratings.