When to Charge for a PT/OT Re-evaluation

December 7, 2020
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We often receive questioned as to when a re-evaluation is necessary (and billable). Therapists are understandably uncertain as to when a re-evaluation can be billed because of conflicting terminology and confusion with “reassessment” requirements in PT and OT Acts.

To determine if and when a re-evaluation is billable, we need to look at all of the following rules:

 The AMA’s CPT descriptions and guidelines for 97164 (PT re-eval) and 97168 (OT re-eval)

 Medicare rules on when a re-evaluation is justified and billable

 Non-Medicare payer rules on when a re-evaluation is justified and billable

 State PT and OT supervision rules requiring therapists to do periodic “reassessments” AMA CPT Guidance

 PT Re-evaluation (97164) The CPT description for a PT re-evaluation (97164) is in italics below: Re-evaluation of physical therapy established plan of care, requiring these components:

1. An examination including a review of history and use of standardized tests and measures is required; and

2. Revised plan of care using a standardized patient assessment instrument and/or measurable assessment of functional outcome

Typically, 20 minutes are spent face-to-face with the patient and/or family.

This means that every time 97164 is billed, regardless of the payer, the elements listed as 1 and 2 above must be completed and documented. The time period of 20 minutes is only mentioned as being typical but is not required. This is not a timed code.

The AMA CPT Assistant, which provides explanations of how CPT codes should be used, includes the following example of a PT re-eval:

A 62-year-old male with low back pain presents for a physical therapy re-evaluation on his eighth visit of his episode of care. The patient had been making progress toward his goals. At his last visit, he reported a reduction in pain from 6/10 to 1/10 and an ability 2 to return to driving and light exercise. However, at this visit, he presents with an increase in pain to 8/10 and describes radiation of pain and sensory loss in the right posterior leg and lateral foot. He is unable to sit for more than 3 minutes. The updated patient medical history is reviewed and current medications are confirmed. The patient’s self-reported and/or performance-based measurement outcome tool is reviewed. The examination during re-evaluation includes measurement of gross range of motion as well as segmental mobility, neurologic status, and muscle strength. The patient’s and/or family/caregiver’s questions are answered as appropriate throughout the re-evaluation. Interpretation of the patient’s response to tests and measures is recorded to assist with updating the plan of care.

OT Re-evaluation (97168)

The CPT description for an OT re-evaluation (97168) is in italics below: Re-evaluation of occupational therapy established plan of care, requiring these components:

 An assessment of changes in patient functional or medical status with revised plan of care;

 An update to the initial occupational profile to reflect changes in condition or environment that affect future interventions and/or goals; and

 A revised plan of care. A formal re-evaluation is performed when there is a documented change in functional status or a significant change to the plan of care is required.

Typically, 30 minutes are spent face-to-face with the patient and/or family.

The AMA CPT Assistant includes the following explanation of an OT re-eval:

Code 97168 is used to report occupational therapy re-evaluation that is based on an established and ongoing plan of care. This is in contrast to the evaluation codes that include development of a plan of care. The AOTA describes a re-evaluation as the “reappraisal of the patient’s performance and goals to determine the type and amount of change that has taken place. Medicare and other third-party payers may have particular rules about when a re-evaluation may be reimbursed. The CPT code set guidelines only describe the components required to report the service. For example, the evaluations codes and the re-evaluation code describe typical time of 30 minutes for face-to-face interaction with the patient and/or family. Again, this is not to be considered a requirement or a limit on time.

In sum, the AMA CPT descriptions provide the basics of when a re-evaluation may be billed and what must be included in a PT and OT re-eval. You should note that Medicare and other payers can and sometimes do impose additional conditions that must be met to be paid for a reevaluation.

Medicare Guidelines

CMS has published fairly extensive guidance as to when a re-evaluation is called for and payable. This guidance is included in Medicare Benefit Policy Manual Ch 15, Section 220.

Under Medicare guidelines, a re-evaluation is medically necessary (and therefore payable) only if the therapist determines that the patient has had a significant improvement, or decline, or other change in his or her condition or functional status that was not anticipated in the POC (emphasis added). Along these same lines, CMS guidance regarding re-evals further provides that:

 Continuous assessment of the patient’s progress is a component of ongoing therapy services and is not payable as a re-evaluation.

 A re-evaluation is not a routine, recurring service, but is focused on evaluation of progress toward current goals, making a professional judgment about continued care, modifying goals and/or treatment or terminating services.

 A re-evaluation is covered only if the documentation supports the need for further tests and measurements after the initial evaluation.

 Indications for a re-evaluation include new clinical findings, a significant change in the patient’s condition, or failure to respond to the therapeutic interventions outlined in the POC.

 A re-evaluation may be appropriate prior to planned discharge for the purposes of determining whether goals have been met, or for the use of the physician or the treatment setting at which treatment will be continued.

 A re-evaluation is focused on evaluation of progress toward current goals and making a professional judgment about continued care, modifying goals and/or treatment or terminating services.

 A re-evaluation should not be routinely required before every progress report but may be appropriate when an assessment suggests changes not anticipated in the original POC.

In addition, the Medicare manual includes the following scenario where a patient on a maintenance program needs intermittent review and possibly a new or revised maintenance program.

EXAMPLE: A patient who has a progressive degenerative disease is performing the activities in a maintenance program established by a therapist with the assistance of family members. The program needs to be re-evaluated to determine whether assistive equipment is needed and to establish a new or revised maintenance program to maintain function or to prevent or slow further deterioration. Intermittent re-evaluation of the maintenance program would generally be covered as this is a service that requires the skills of a therapist. Should the therapist conducting the re-evaluation determine that the program needs to be revised, these services would generally be covered.

In sum, Medicare does not allow for routine re-evals as the patient progresses through his or her POC. For example, a re-evaluation should not be charged for every 10th visit requiring a progress note unless the assessment indicates changes not anticipated in the original POC.

Non-Medicare Payer Rules

The major commercial payers and Tricare do not have any unique guidance regarding re-evals. Their PT/OT policies basically include the AMA’s CPT descriptions for 97164 and 97168 if they include anything at all.

Medicare’s more restrictive re-evaluation rules do not necessarily apply to these payers. Instead, therapists can rely on the AMA’s descriptions of 97164 and 97168 (see above) to determine whether a re-evaluation is indicated and billable. While Medicare rules are more restrictive than the CPT descriptions, a change in patient condition indicating the necessity for a change in the POC is still required per the AMA.

State PT/OT Acts

Many state PT and OT Acts and related regulations require therapists who are supervising assistants and aides to periodically reassess the patient’s progress. For example, the North Carolina PT rules state that:

If a physical therapist assistant or physical therapy aide is involved in the patient care plan, a physical therapist shall reassess a patient every 60 days or 13 visits, whichever occurs first.

These requirements to periodically reassess the patient are supervisory rules and do not in and of themselves indicate that a re-evaluation should be charged for every reassessment. Therapists should instead look to the Medicare rules for Medicare patients or the AMA CPT rules for non-Medicare patients to determine whether the PT or OT re-evaluation code can be billed as discussed above.