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Massage Today
September, 2002, Vol. 02, Issue 09

CPT Code 99201 and All 99 Codes

By Ed Denning, MEd, LMT

Some massage therapists are being encouraged to use 99201 and other codes that begin with 99 to report office or other outpatient visits for the evaluation and management of new patient.

I strongly recommend not using any codes beginning with 99 by any massage therapist who is also not a physician. These are physician codes only.

Going beyond opinion, I cite the following information:

1. Page 9 of the 2002 CPT Manual* lists and defines code 99201 in this manner: Office or other outpatient management of a new patient, which requires these three key components:

  • a problem-focused history;
  • a problem-focused examination;
  • straightforward medical decision-making.

2. Page 6 of the manual defines medical decision-making in this manner:

Medical decision-making refers to the complexity of establishing a diagnosis and/or selecting a management option as measured by:

  • the number of possible diagnosies and/or the number of management options that must be considered;
  • the amount and/or complexity of medical records, diagnostic tests, and/or other information that must be obtained, reviewed and analyzed;
  • and the risk of significant complications, morbidity, and/or mortality, as well as comorbidities, associated with the patient's presenting problems(s), the diagnostic procedure(s) and/or the possible management options.

Pay special attention to how the three qualities of medical decision-making noted above tie together. They are listed with semi-colons and the word "and," meaning that medical decision-making must include all three qualities. There is no selectivity in the statements. All three must be present present for proper use of the code.

Straightforward medical decision-making has a component that requires the clinician to make decisions regarding "the risk of significant complications, morbidity and/or mortality ..." Massage therapists are not qualified to make decisions regarding complications, morbidity or mortality.

Additionally there is a table on page 7 of the manual that I believe clearly ties straightforward decision-making with decisions regarding complications and/or morbidity or mortality.

For the reasons listed above, I urge all massage therapists who do billing to stop using 99 codes. Even if the use of such codes is accepted by an insurance company, it carries with it a risk that a change of policy, applied retroactively, could result in significant problems for the therapist. It is your responsibility to use the correct code. If an insurance company tells you to use a 99 code, get the company's recommendation in writing.

For those who want to use CPT codes that apply to office visits, at this time my only recommendation is that you appeal to your associations to pursue the creation of CPT codes designed specifically for massage therapy. Only associations would be able to get new CPT codes approved by the American Medical Association (AMA).

It is not difficult or dangerous to use CPT codes, but like anything else, it takes time and patience. I recommend that massage therapists use only those codes for which there is documentation. Using a code that has not been established through documentation is to assume (perhaps naively) that you have been taught correctly.

*American Medical Association, Current Procedural Terminology, CPT 2002 Standard Edition; Chicago, Illinois 60612.

Ed Denning is a licensed massage therapist in Ohio. He is coordinator of the massage therapy program at Stark State College of Technology, and also serves on the Massage Therapy Advisory Committee of the Ohio State Medical Board.


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