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Diagnostic Services by Physical Therapists

Physical Therapists (PTs) who are board-certified in clinical electrophysiology by the American Board of Physical Therapy Specialties (ABPTS) are recognized by CMS to furnish certain diagnostic services involving electromyography (EMGs), nerve conduction velocity (NCVs), and sensory evoked potentials (SEPs) when the service is permitted under state law.  

Diagnostic tests are covered as “other diagnostic tests” under section 1861(s)(3) of the Social Security Act (the Act) and payable under the physician fee schedule (PFS). These tests are not considered outpatient physical therapy services covered under section 1861(p) of the Act; and, as such, may not be reported with a ─GP modifier on the claim line of service.

CMS payment policy and the related code list for EMGs, NCSs, and SEPs was initially implemented through Transmittal B-01-28 that became effective July 1, 2001. This policy is based on the regulation at 42 CFR 410.32(b)(2)(iv) which excepts physician supervision for certain diagnostic tests personally performed by ABPTS-certified PTs when they are legally providing the services in accordance with state law. CMS has assigned these PT-designated diagnostic services a physician supervision indicator (PSI) of “21,” “66,” “6A,” “77,” or “7A” on the technical component (TC) code.

CMS assigns “09” PSIs, meaning that physician supervision does not apply, to the global and the professional component (PC) codes of these PT-designated diagnostic services. Consistent with regulation, payment can be made for the PC or global code to the ABPTS-PT, as long as it is legal for the ABPTS-PT to provide the TC and interpretive service in that state, and the TC has been either personally performed by the ABPTS-PT or the PT without the ABPTS certification has met the supervision requirements for the TC portion of the service consistent with the applicable PSI.

For the PSI full descriptors, refer to the Medicare Physician Fee Schedule layout file in the applicable year’s “Addendum – MPFSDB Record Layouts” section found in the Medicare Claims Processing Manual Chapter 23. In order to see which PSIs are assigned to particular codes, visit the most recent PFS Relative Value (PFS RVU) on the PFS webpage. This PFS RVU file also includes an RVU.pdf document that lists the PSI full descriptions (see field for Physician Supervision of Diagnostic Procedures), including any quarterly updates.

Please refer to the list of codes that are currently applicable to the diagnostic services furnished by the ABPTS-certified PT, who is legally furnishing these services in accordance with state law.

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