Both chiropractors and orthopedic surgeons alike will perform manual muscle testing billed under either CPT codes 95851 or 95832 along with a 99205, 99204 or 99203 office visits. Insurance companies regularly deny manual muscle testing CPT codes on the grounds that the manual muscle testing is bundled into office visits and therefore is not a separate billable medical service. For both CPT codes, there must be a separate manual muscle testing report that specifically sets forth the results of each manual muscle test, the need for the muscle test and the signature of the physician.
There is an appellate opinion from the Fourth District Court of Appeal that interprets manual muscle testing billed under CPT code 95832 and the Court required a separate manual muscle test report consisting of specifying each measurement of the muscle testing, the need for a muscle testing and a signature of the physician. The District Court of Appeal frowned on an office visit report that specifically referred to manual muscle testing. The District Court of Appeal found that under those facts, the manual muscle testing was part of the initial office visit report and therefore could not be separately billed.
For CPT code 99851, I have seen that some insurance companies claim that the Medicare guidelines requires a manual muscle testing to take place and to be billed on a separate day from office visits. I have read the Medicare guidelines and it is ambiguous as to whether the manual muscle testing is required to take place and to be billed on a separate day from office visits.
Although the Fourth District Court of Appeal opinion involves CPT code 95832 instead of CPT code 95851, both codes are manual muscle testing and the Fourth District Court of Appeal opinion should apply to CPT code 95851 and CPT code 95832.
As a belt and braces tactic to avoid denials of manual muscle testing on the grounds of improper bundling, a medical provider should perform and bill manual muscle testing on different dates that there is an office visit. However, it is not mandatory. The long and short of it is that if an insurance company declines paying manual muscle testing CPT codes for not being billed on the same day as an office visit, there is an opinion from the District Court of Appeal that does not make that requirement. As a PIP suit lawyer, I have run across this issue on various occasions and have been successful in getting medical providers paid for their services.
George A. David, Esq.
