Should ROM Testing be Reported with Evaluation and Management Services?

by  Aimee Wilcox, CPMA, CCS-P, CST, MA, MT
January 9th, 2018

We recently received an email from a reader asking whether or not range of motion (ROM) testing (95851-95852), using a duel computerized inclinometer with a separate report when done at the same time as an Evaluation and Management (E/M) service, could be billed together if modifier 59 was added to override the NCCI edit. The reader referred to the patient's condition indicating the need for “more definitive and quantifiable data” and referred to the specific ROM Assessment guides set by the AMA.

Although it may seem justifiable and even medically necessary to perform these services simultaneously, CMS has determined they are incidental to each other. This means the work involved in performing the Column 2 (ROM testing) code is included in the work required to perform the Column 1 (E/M service) code, so only the Column 1 code (E/M service) will be paid if they are billed on the same date by the same provider.

According to the National Correct Coding Initiative (NCCI) edits, when range of motion (ROM) testing is performed (95851-95852) at the same time as an Evaluation and Management (E/M) service, the ROM testing will be denied as incidental (or an expected part of) the physical examination portion of the EM service. A quick look at the NCCI table associated with these code combinations shows a modifier indicator of "0." The indicator "0" means an acceptable NCCI modifier to override the edit does NOT exist and if modifier 25 or modifier 59 were added to the ROM code, the service would still be denied as included in the E/M service. Medicare addresses exactly this situation in the Medicare Benefit Policy Manual, Chapter 15, Section 240.1.2:

A subluxation may be demonstrated by….Physical Examination evaluation of the musculoskeletal/nervous system to identify:

  • Pain/tenderness evaluated in terms of location, quality, and intensity;
  • Asymmetry/misalignment identified on a sectional or segmental level;
  • Range of motion abnormality (changes in active, passive, and accessory joint movements resulting in an increase or a decrease of sectional or segmental mobility); and
  • Tissue, tone changes in the characteristics of contiguous, or associated soft tissues, including skin, fascia, muscle, and ligament.

To demonstrate a subluxation based on physical examination, two of the four criteria mentioned under “physical examination” are required, one of which must be asymmetry/misalignment or range of motion abnormality."

Additionally, according to the NCCI edits ROM testing can be reported with certain critical care E/M services but these would not likely be performed by Chiropractors in the hospital setting.

So, when can ROM testing be reimbursed?

A provider, properly educated, licensed and allowed under state practicing laws, who performs ROM testing (95851 - 95852) as a separate and independent service, could be eligible for reimbursement, as long as a separate written report identifying any findings is included in the medical record.

Many physical therapists routinely perform both ROM testing (95852-95852) and manual muscle testing (MMT) (95831 - 95834) as a routine part of 97750. In this situation, ROM and MMT would not be separately billable, but rather would be billed as part of 97750 instead. 

A caveat about this code many providers forget, is that the description for 95851 is for range of motion testing per extremity (each extremity), meaning for each extremity, you can bill one (1) unit of service but that ROM testing should be done for each joint pertaining to that extremity and documented to show it was done. Documentation must clearly identify the complete ROM testing for each extremity for which a single unit of service can then be reported. 

The specialized software for ROM testing is useful for many providers; however, the circumstances surrounding the test, and other services performed at the same encounter, will completely determine whether or not these services are reimbursable or considered incidental to the other services provided. To ensure proper reporting, always check your codes using the NCCI Validator Tool, available through certain Find-A-Code subscriptions.




Should ROM Testing be Reported with Evaluation and Management Services?. (2018, January 9). Find-A-Code Articles. Retrieved from

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