Billing for Manual Therapy and Determining Proper CPT Codes


Question: I have worked as a physical therapist for the past two years and have worked for a variety of outpatient clinics including small therapist-owned companies, large national corporations and hospitals. I cannot count the number of times these facilities have used massage therapists, physical therapy technicians and athletic trainers (ATC) to provide a hands-on portion of the treatment session, and billed Medicare for the time as physical therapy. Is this legal in any of those settings? I believe in using massage and other manual therapies, and I know the patients like it and likely benefit from it. But I thought billing 97140 and 97124 required the skills of a physical therapist or physical therapist assistant when treating physical therapy patients.

Also, do you know if payers other than Medicare have their own policies for using CPT 97140 and 97124?

Answer: We also believe in massage and manual therapy as beneficial therapeutic agents. According to the Code of Federal Regulations, Title 42 (which are the Medicare regulations) if treatment is being billed as physical therapy in any rehabilitation setting, it must be given by a physical therapist or physical therapist assistant (under the supervision of a physical therapist). Billing Medicare for massage given by a massage therapist or exercise given by an ATC is fraud.

It is interesting to note that allowing massage therapists, ATCs and rehabilitation technicians to provide any skilled service in physical therapy is also against many state practice acts for physical therapy. For example, in Florida, therapists are forbidden by law to delegate any skilled intervention to anyone lesser trained than a PT assistant. All payers have policies for the use of CPT codes. Many follow Medicare guidelines.

Question: I have a question about Common Procedural Terminology (CPT) codes for speech therapy. I work for two different contract companies providing therapy to patients in a long-term care facility. One company has told me that I can charge code 97110 (therapeutic exercise) for therapy such as oral motor exercises, and code number 97531 (therapeutic activity) for things like "rehab dining," by which I'm assuming they mean training in the use of compensatory strategies for swallowing, etc. Also, I have been told on occasion that code number 97112 (neuromuscular re-education) can be used for thermal stimulation therapy.

I would like to know the "bottom line" verdict on these codes. I have never seen these used for anything but physical and occupational therapy. The company wants me to use the codes in place of the traditional codes 92507 and 92526 (treatment of speech, language, voice, communication and treatment of swallowing dysfunction and or oral function for feeding, respectively) because the "speech" codes are non-timed, thus billable at a much lower rate.

I know that upcoding is fraud, and will not participate in such an activity, but I want black and white proof that I know what I'm talking about before I launch into a big ethics battle with my employer. If you could direct me toward a site or contact where I can find exactly what is a reimbursable CPT code for speech therapy, I would be eternally grateful.

Answer: The Medicare Advisors believe that we could make a good argument for use of code 97110 (more so than 97530 or 97112) by speech pathology. But alas, it is not up to us.

The "bottom line" verdict on these codes is up to your facility's fiscal intermediary or carrier. If they allow the use of codes 97110, 97530, and 97112 for speech pathology services, then this would not be considered upcoding and would be acceptable.

Your fiscal intermediary or carrier should have a Website with this information on it, or the Website will direct you to their list of acceptable codes. Some fiscal intermediaries and carriers probably have edits against the use of these codes by speech pathology.


1. National Archives and Records Administration (October 1, 2000). Code of federal regulations. Title 42. Washington, DC: Dept. of HHS.

2. Florida Administrative Code. Chapter 64B17-6.001 (5)(c)3.d.

  • If you have a question about Medicare reimbursement you would like the authors to address, send your question and contact information to Medicare Advisor, c/o Linda Jones, ADVANCE for PTs & PTAs, 2900 Horizon Dr., King of Prussia, PA 19406; fax (610) 278-1425; ljones@merion.com.

    Pauline Watts and Danna Mullins are the co-founders of and principal lecturers for Encompass Education Inc., a rehabilitation education and consulting firm in Palm Harbor, FL. You may contact the authors at medicareadvisor@encompasseducation.com


    Can PTAs bill manual therapy (code 97140) in the state of Pennsylvania?

    Krystal November 07, 2015


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