An Update on Outpatient Therapy Services

The Centers for Medicare & Medicaid Services (CMS) recently issued a Medicare Learning Network (MLN) Matters article listing the therapy codes for calendar year (CY) 2010. Specifically, CMS has updated the therapy codes list by adding Healthcare Common Procedure Coding System/ Current Procedure Terminology 2010 Edition (HCPCS/CPT) code 95250 (Larngeal function studies) and deleting HCPCS/CPT code 95992 (Standard Canalith reposition procedures). CMS also requested that Medicare contractors offer compliance education to providers on outpatient therapy services. In line with this recommendation, this article aims to provide an overview on correct billing and coding practices for outpatient therapy services.

What are therapy services and who can bill for these services?
According to CMS, therapy services include physical therapy, occupational therapy, and speech‐language pathology services. Under section 1834(k)(5) of the Social Security Act, a uniform coding system is required for all outpatient rehabilitation therapy services and comprehensive outpatient rehabilitation facility services. CMS uses the HCPCS/CPT as the coding system to report these services.  The following providers are required to bill their Medicare contractor for outpatient rehabilitation services using the HCPCS/CPT cod

  • Comprehensive outpatient rehabilitation facilities;
  • Home health agencies;
  • Non‐physician practitioners (e.g. nurse practitioners and clinical nurse specialists) who are performing services within their State scope of practice;
  • Occupational therapists in private practice
  • Other rehabilitation facilities;
  • Physical therapists in private practices;
  • Physicians (including MDs, DOs, podiatrists, and optometrists);
  • Providers of outpatient physical therapy and speech‐language pathology services providers;
  • Skilled nursing facilities;
  • Speech‐language pathologists in private practices; and
  • Hospitals (only for outpatients and inpatients that are not in a covered Part A stay).

What are the therapy codes and where can I find them? As noted above, CMS updated the therapy code list for CY 2010. The updated therapy code list went into effect January 1, 2010 and is posted below. The list is also located on CMS’ website at: