Local Coverage Article Response to Comments

Response to Comments: Respiratory Care (Respiratory Therapy)


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Response to Comments: Respiratory Care (Respiratory Therapy)
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Response to Comments
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Noridian's response to provider recommendations (for comment period ending 08/14/2017)

Response To Comments


One commenter suggested clearer language in the following statement:

  • diagnostic tests for evaluation by a physician (e.g., pulmonary function test, spirometry, and blood gas analyses).

We will change the language to read "diagnostic tests ordered by and for the evaluation by a physician or NPP (e.g., pulmonary function test, spirometry, and blood gas analyses etc.)".


Another commenter wrote: I'm very concerned about the plan to discontinue payment for respiratory viral PCR and stool PCR's.

We agree that respiratory viral PCR and stool PCR tests have a place in the diagnosis and potential treatment of respiratory diseases, we do not think they fit into this specific policy of Respiratory Care therapy as such.


Initial education of patients in the proper use of metered dose inhalers, dry powder inhalers, breath-activated inhalers and nebulizers are a key aspect for successful therapy for respiratory diseases like asthma and COPD. The initial education involves considerably more staff time than refresher training that occurs at follow-up visits. There is a defined CPT code for this procedure, 94664, "Demonstration and/or evaluation of patient utilization of an aerosol generator, nebulizer, metered dose inhaler or IPPB device".

Thank you for the comment. CPT code 94664 is in the Draft LCD and will continue to be part of the CPT codes in this Final policy.


One individual asked that we include the following ICD-10-CM codes to the policy:

  • J70.4 - drug -induced interstitial lung disorders, unspecified
  • J18.9 - Pneumonia, unspecified organism
  • J34.9 - Emphysema
  • J84.9 - Interstitial pulmonary disease, unspecified
  • R06.00 - Dyspnea, unspecified
  • J84.10 - Pulmonary fibrosis, unspecified
  • G47.34 - Idiopathic sleep related nonobstructive alveolar hypoventilation
  • Z01.818 - Encounter for other preprocedural examination
  • R07.89 - Other chest pain
  • D86.9 - Sacroidosis, unspecified
  • J18.9 - Pneumonia, unspecified organism
  • J45.909 - Unspecified asthma, uncomplicated
  • J43.9 - Emphysema, unspecified
  • J45.901 - unspecified asthma with (acute) exacerbation

We feel that these "unspecified" or "other" codes in the environment of ICD-10-CM already have more granular specified codes in the draft that better serve understanding the underlying disease states that these patients have.


One commenter felt that there was inconsistency in one of the explanatory paragraphs.

"...Medicare coverage of respiratory care (respiratory therapy) provided as outpatient hospital or extended care services depends on the determination by the attending physician (as part of his/her plan of treatment) that for the safe and effective administration of such services the procedures or exercises in question need to be performed by a respiratory therapist, physical therapists, nurses, and other qualified personnel as described by relevant state practice acts as listed above. In addition, Medicare may cover postural drainage and pulmonary exercises furnished by a respiratory therapist as incident to a physician's professional service. In order to be considered for reimbursement by Medicare, respiratory therapy services must be fully documented in the medical records. The documentation must clearly indicate that the services rendered were reasonable and medically necessary and required the skills of a licensed respiratory therapist.

We will remove the language "...and required the skills of a licensed respiratory therapist" noted above.


This Respiratory Care LCD includes coverage for "diagnostic tests for the evaluation by a physician (e.g., pulmonary function test, spirometry and analyses)" and also includes overlapping medical necessity requirements and CPT codes with Draft/Proposed LCD  Pulmonary Function Testing. Please consider removing the Pulmonary Function Testing requirements and associated CPT codes from the draft respiratory therapy policy and including all Pulmonary Function Testing requirements and CPT codes in Pulmonary Function Testing as it gets confusing when there are two different policies for the same service. Please consider removing the following CPT codes from Respiratory Therapy as they are already addressed in Pulmonary Function Testing:

  • 94010 - Breathing Capacity test
  • 94011 - Spirometry up to yrs old
  • 94012 - Spimtry w/brnchdil inf-2yr
  • 94013 - Meas lung vol thru 2 yrs
  • 94060 - Evaluation of wheezing
  • 94070 - Evaluation of wheezing
  • 94150 - Vital capacity test
  • 94200 - Lung function test (mbc/mvv)
  • 94250 - Expired gas collection
  • 94375 - Respiratory flow volume loop
  • 94400 - Co2 breathing response curve
  • 94450 - Hypoxia response curve
  • 94620 - Pulmonary stress test/simple
  • 94621 - Pulm stress test/complex
  • 94640 - Airway inhalation treatment
  • 94664 - Evaluate pt use of inhaler
  • 94726 - Pulm funct tst plethysmograp
  • 94727 - Pulm function test by gas
  • 94728 - Pulm funct test oscillometry
  • 94729 - Co/membane diffuse capacity
  • 94750 - Pulmonary compliance study

We feel that the codes listed above are necessary and should remain (along with the associated diagnoses) in this policy. The tests may be used along with some aspects of pulmonary therapy. Noridian, in an effort to avoid confusion, will ensure the diagnosis codes will be reimbursed in both policies.

Associated Documents

Related Local Coverage Documents
L34149 - Respiratory Care (Respiratory Therapy)
Related National Coverage Documents
Public Versions
Updated On Effective Dates Status
05/10/2018 07/09/2018 - N/A Currently in Effect You are here


  • Respiratory Care
  • Therapy
  • Therapist