The Range of Motion Conundrum

by  Gregg Friedman, DC CCSP
Jun 7th, 2018 - Reviewed/Updated Jan 30th

As both a chiropractor for 31 years and one who reviews a lot of medical records for the medicolegal arena and has been teaching documentation for many years, the range of motion question comes up frequently. Although we used to get reimbursed very well for a specific range of motion code back in the 90’s, it’s pretty much disappeared from insurance reimbursement, other than for personal injury cases. Even other record reviewers get this one wrong, so I’ll keep this as simple as possible.

There is a specific CPT code for Range of Motion Measurements – 95851 (Range of motion measurements and report (separate procedure); each extremity (excluding hand) or each trunk section (spine)). The long-standing problem with this code has been, if it’s performed and billed on the same visit as your ortho/neuro exam, which was billed as an E/M code, insurers and reviewers will usually deny the 95851 code, accusing you of the dreaded “unbundling” error. The problem is…they’re WRONG.

The insurer’s position is that range of motion is part of your ortho/neuro exam, for which you billed an E/M code. They’re partially correct. The insurers love to refer back to the 1997 Documentation Guidelines for Evaluation & Management Services. When reviewing the Musculoskeletal section, it says, “Assessment of range of motion with notation of any pain (e.g., straight leg raising), crepitation or contracture.” In other words, the doctor can simply perform a visual assessment of range of motion, noting pain, or a palpatory assessment of range of motion, noting crepitation or contracture. There is no mention of measuring range of motion.

In order to properly bill the 95851 code, it requires 2 items: actual measurements (not an eyeball estimate) and a written report. That’s it. The code is billed in units for each extremity (excluding hand) and each trunk section (spine). If you have a diagnosis related to the cervical OR lumbar spine, and you measure one OR the other, you would bill the code with one unit. If you have  diagnoses related to the cervical AND lumbar spine, and you measure BOTH cervical and lumbar ranges of motion, you would bill the code with two units.

I’ve been measuring range of motion on patients for more than 20 years, and have billed the 95851 code the entire time, usually on the same visit as the ortho/neuro exam, so I bill the E/M code AND the 95851 code for measured range of motion. I always send my records with the bill and include a report for the range of motion measurements. Like many others, I’ve had the code denied by auto carriers.

But I fight it – every time.

And I’ve won – every time. In fact, all I have ever had to do was to speak with the adjuster and tell them I’m appealing the denial. They reply, “Let me take a look – Oh, yes, I see you sent in a written report. I’ll go ahead and send payment.” If you try that and it doesn’t go quite as easily for you, I would send them a copy of the 1997 Documentation Guidelines (https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/downloads/referenceii.pdf), page 32, along with my earlier explanation of “noting pain, crepitation or contracture.”

If they still don’t cave to your brilliance, I send them a copy of a letter I received from the AMA CPT Information Services back in 2004, in which the coding consultant wrote, “Code 95851 identifies manual or computerized range of motion measurements.  This service requires that an actual measurement is performed. Statements regarding range of motion do not qualify as provision of a range of motion procedure as identified by code 95851-95852. The above services require provision of a distinct report identifying the results of the testing procedures performed.”  The AMA consultant goes on to say, “However, if a separate distinctly identifiable evaluation and management (E/M) service is provided in addition to these services, then it would be appropriate to report a separate E/M code. In this circumstance, modifier 25 is appended to the appropriate level E/M service code to identify that service as a significant, separately identifiable E/M performed in addition to the 95831-95834/95851-95852 services.”

But there’s a catch.

If your plan is to do these measurements just to jack your PI bill up some more, we’ll figure that out. We’ll challenge you as to “how did it change your treatment plan?” Many doctors who bill this code document little to nothing as to how it affected their treatment plan.  It should be included in your measurable goals. You should document if the range of motion limitations are improving or not with your treatment, and, if not, what will you change in your treatment.  Without that, we’ve got you by the, um…inclinometer. Speaking of that, if you want to measure the spine, use dual inclinometers. For the extremities, use a goniometer. Period. Those are the standards, like ‘em or not.

If you have any questions or want to yell at me (other medicolegal reviewers most likely) or even if you want a copy of the letter from the AMA, just e-mail me at drgregg@thebulletproofchiro.com.