CurrentCignaPolicy N/A

Therapy Services Range of Motion Testing

Defines clinical coverage criteria, documentation requirements, and coding guidance for CPT codes 95851 and 95852 for range of motion testing when services are beyond standard E/M or therapy evaluations and are necessary to develop a plan of care for patients with complex multi-extremity/trunk conditions.

Policy Summary

PayerCigna

PolicyTherapy Services Range of Motion Testing

Policy CodePolicy N/A

Change TypeNo material change

Effective DateJun 15, 2025

Next Review DateJun 15, 20267d

Key ActionWhen billing CPT 95851 or 95852, provide the practitioner's interpretation and a separate, distinct, dated and signed written report that documents purpose/rationale, tests performed, results, and how results affect the treatment plan.

POLICY UPDATE CHANGES

No material clinical or coverage changes stated in this brief.

2Covered CPT Codes

4Related Evaluation/Re-evaluation Codes Mentioned

4Example Complex Conditions Listed

Coverage Summary

Scope: This policy defines coverage criteria, documentation requirements, and coding guidance for CPT 95851 and 95852 (range of motion testing) and applies when these services are provided as separate procedures with practitioner interpretation and a distinct written report. Effective date: 2025-06-15. Coverage stance: covered with criteria — 95851-95852 are covered when the policy's medical necessity criteria and documentation requirements are met. Related therapy and E/M evaluation/re-evaluation codes (e.g., 97161-97164, 97165-97168 and typical E/M services) ordinarily include ROM and baseline measurements and are considered incidental to those services; ROM testing is covered separately only when it is beyond what is included in those evaluations and is necessary to develop the plan of care.

Medical Necessity Criteria

Medically Necessary

Range of Motion (ROM) Testing is considered medically necessary when ALL of the following are met:

ALL of the following

Patient has medical conditions that impact multiple extremities and trunk musculature (examples include but are not limited to: spinal cord injury; traumatic brain injury; neurologic conditions e.g. multiple sclerosis, stroke; movement disorders e.g. Parkinson's disease, cerebral palsy).
Further testing or evaluation beyond what is included in the Evaluation and Management (E/M) service or standard physical therapy, occupational therapy, or athletic training evaluation/re-evaluation service is required to develop a plan of care.
Testing is pertinent to the plan of care and the diagnosis.
A written report with interpretation of the results is provided; the practitioner's interpretation and a separate, distinct, dated and signed written report are required.
See documentation guidelines: report should indicate purpose/rationale, tests performed, results, and how results affect the treatment plan.
When coding, every muscle or joint in the affected extremity or trunk section as described in the code descriptor must be tested (e.g., 95851 requires testing every joint of an extremity or trunk section).
It would not be appropriate to submit code 95851 if only a single joint (e.g., shoulder) needed testing.

Not Routinely Necessary / Exclusion Guidance

ROM testing is NOT considered reasonable or necessary when used routinely or as a substitute for standard evaluation/reevaluation services:

ALL of the following

ROM codes 95851-95852 should not be performed on a routine basis (e.g., monthly) or in place of a standard reevaluation/E/M code.
Baseline measurements done as part of an initial E/M, physical therapy evaluation/reevaluation (97161-97164, 97165-97168) are considered incidental and included in that service and are not separately billable as 95851/95852.
Use of digital devices that provide reports does not by itself justify use of 95851/95852.

Provider Actions & Billing Guidance

Documentation Required

Report and Interpretation Required

CPT 95851 and 95852 require the practitioner's interpretation of the results and a separate, distinct, dated and signed written report. The report should document the purpose and rationale for testing, the specific tests performed with results, and how the results affect the treatment plan.

Affected codes: 95851, 95852
Required report elements: purpose/rationale
Required report elements: tests performed and results
Required report elements: how results affect the treatment plan
Report must be separate, distinct, dated and signed and include practitioner's interpretation

Billing Rule

Complete Testing Required for Code Selection

When reporting 95851 or 95852, every muscle or joint in the affected extremity or trunk section described by the code descriptor must be tested and documented. Code selection must reflect complete testing per the descriptor; for example, 95851 (each extremity or trunk section) should not be used if only a single joint (e.g., shoulder) was tested.

Affected codes: 95851, 95852
95851 not appropriate for single-joint testing (must test entire extremity or trunk section)

Denial Risk

Claims Denied If Not Accompanied by Covered Diagnosis/Documentation

Claims for 95851/95852 will be denied when services are not accompanied by covered diagnosis/procedure codes or when documentation does not meet policy criteria. Denials commonly occur if there is no separate report with interpretation, the testing is not pertinent to the plan of care or is merely routine/baseline/incidental to an E/M or therapy evaluation, or if testing was performed as a substitute for standard evaluation/reevaluation services.

Affected codes: 95851, 95852
Common denial triggers: missing separate dated/signed report with interpretation
Common denial triggers: testing is incidental to or included in initial E/M or therapy evaluation/re-evaluation (97161-97168)
Common denial triggers: routine or substitute testing (e.g., monthly) or baseline measurements included in evaluations
Common denial triggers: claims submitted without covered diagnosis or procedure codes under this policy

Background & Evidence

Background: For the typical patient, E/M services and standard physical or occupational therapy evaluations and re-evaluations (codes 97161-97163, 97164, 97165-97167, 97168) include objective measurements such as range of motion and baseline measurements, which are considered incidental to those services and not separately billable. ROM testing (CPT 95851-95852) are designated as separate procedures that require the practitioner's interpretation and a separate, distinct, dated and signed written report. Testing should be relevant to the plan of care and the diagnosis; every muscle or joint in the affected extremity or trunk section described by the code descriptor must be tested when coding these procedures (for example, 95851 requires testing every joint of an extremity or trunk section and should not be used if only a single joint is assessed). These codes are typically consultative and the generated report should document purpose/rationale, tests performed, results, and how results affect the treatment plan. ROM testing may be appropriate as a separate, specialized test for patients with complicated conditions who need additional objective measures to inform the plan of care.

Evidence / Source	Summary
Cools et al. (2014)
Found good-to-excellent reliability for shoulder internal and external rotation ROM and isometric strength measurements (ICC acceptable); procedures examined showed acceptable reliability for clinical use, though position and equipment may influence results.
Systematic reviews (Beshara 2021; Hahn 2021; Elgueta-Cancino 2022)
Mixed evidence: Kinect, inertial sensors, smartphone apps and digital inclinometers/goniometers show moderate-to-good intra- and inter-rater reliability for certain joints (shoulder, knee, ankle, neck); overall quality and applicability vary and evidence is limited for some joints (hip lacking).
CMS Guidance
Evaluations and re-evaluations include objective measurements (including ROM) and baseline measurements are typically incidental; on rare occasions thorough ROM testing may be separate from evaluation/re-evaluation (CMS LCD L33631, 2020).

Definitions: ROM testing (CPT 95851-95852) — range of motion measurements and report performed as separate procedures that require full testing of every muscle/joint in an extremity or trunk section as described by the code descriptor and a separate, distinct, dated and signed written report with the practitioner's interpretation. CPT descriptors: 95851 = each extremity (excluding hand) or each trunk section (spine); 95852 = hand, with or without comparison with normal side. These procedures are distinct from routine baseline ROM measurements performed within an E/M or therapy evaluation/re-evaluation, which are considered included in those services.

Name	Number	Type	Effective Date
{"text":"Outpatient Physical and Occupational Therapy Services","status":""},{"text":"L33631","status":""},{"text":"LCD","status":""},{"text":"2020-01-01","status":""}