Diagnostic Services by Physical Therapists

CMS recognizes physical therapists (PTs) who are board-certified in clinical electrophysiology by the American Board of Physical Therapy Specialties (ABPTS) 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.  

Medicare covers these services as “other diagnostic tests” under section 1861(s)(3) of the Social Security Act and they're paid under the Physician Fee Schedule (PFS). Since these tests aren't considered outpatient physical therapy services covered under section 1861(p) of the Social Security Act, you may not report these tests with a ─GP modifier on the claim line of service.

When Did This Payment Policy Begin?

Effective July 1, 2001, CMS implemented payment policy and the related code list for EMGs, NCVs, and SEPs (see Transmittal B-01-28 (PDF)). 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're legally providing the services in accordance with state law. 

What Physician Supervision Indicators Apply?

CMS has assigned these PT-designated diagnostic services 1 of the following physician supervision indicators (PSIs) on the technical component (TC) code:

• 21
• 66
• 6A
• 77
• 7A

CMS assigns “09” PSIs, meaning that physician supervision doesn't apply to the global and the professional component (PC) codes of these PT-designated diagnostic services. Consistent with regulation, Medicare can pay for the PC or global code to the ABPTS-PT, if both of these apply:

• It's legal for the ABPTS-PT to provide the TC and interpretive service in that state
• The TC has been either personally performed by the ABPTS-PT or the ABPTS-PT has personally supervised the PT without the ABPTS certification

View the Code List for Diagnostic Services by PTs (PDF), including applicable PSIs.

• For the PSI full descriptors, see the Medicare Claims Processing Manual Chapter 23 (PDF). Go to the applicable year’s “Addendum – MPFSDB Record Layouts” section, and find the Medicare Physician Fee Schedule layout file. 
• 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.