[This article has been revised from the original post on Jan. 5 to update language that was inaccurate. APTA regrets the error.]
In another win for providers trying to square best practices with coding rules, CMS has announced that manual therapy can be reported in the same session as codes related to application of a multi-layer compression system.
Specifically, according to the most recent National Correct Coding Initiative edits to chapter 4, section G.17 of the policy manual, providers generally can now use CPT codes 29581-29584 (multi-layer compression systems) during the same episode as code 97140 (manual therapy) — a combination that often makes clinical sense, but wasn't always permitted.
The problem can be traced back to 2018, when a change was made in the CMS coding manual replacing the words "should not" with "shall not" in reference to billing manual therapy and multi-layer compression together. In 2021, Medicare administrative contractors began denying claims that reported the two types of codes, based on the 2018 change in the manual language. APTA pushed back, submitting a letter to CMS and its vendor in charge of the NCCI arguing that the change resulted in inappropriate denials of appropriate care.
CMS responded by updating the language in the manual to indicate that these procedures may in fact be billed together during the same patient encounter if clinically appropriate. However, the combination of codes still is prohibited when 29581-29584 are used specifically during treatment of lymphedema, and APTA is now seeking clarification from CMS regarding this non-coverage.
As in previous changes to NCCI coding edits — most notably around code-pairing restrictions — the shift was advocated by APTA, which argued that the prohibition ran counter to best practice. In the most recent case, the association asserted that manual lymphatic drainage techniques are often required before compression systems are applied.
In terms of exactly how the codes should be reported, CMS advises that it may be necessary to use the 59 or X modifier to indicate that the two activities are distinct from each other. APTA provides guidance on the use of the X and 59 modifiers in this easy-to-use decision tree.