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97161-97163 CPT Codes: PT Evaluation Complexity Tiers

Last Updated: October 23, 2025

Unlike standard physician E/M visits, Physical Therapy evaluations are strictly categorized into three tiers of complexity: Low, Moderate, and High. All three codes pay the exact same amount under Medicare, but using the wrong code is an audit violation.

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2026 Medicare National Fee (97161): Non-Facility (Office): $121.46 · Facility (Hospital): $121.46
✓ 25,764 Medicare-Approved ICD-10 Diagnoses on file for 97161:

The Three Complexity Tiers

  • 97161 (Low): No personal factors/comorbidities affecting the plan. 1-2 elements examined. Stable presentation.
  • 97162 (Moderate): 1-2 personal factors/comorbidities. 3 or more elements examined. Evolving/changing characteristics.
  • 97163 (High): 3+ personal factors/comorbidities. 4 or more elements examined. Unstable/unpredictable presentation.

Untimed Codes

PT Evaluations are untimed. Whether the evaluation takes 20 minutes or 60 minutes, you only bill 1 unit of the evaluation code.

NCCI Edits

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Not sure if these codes bundle? Check the latest Medicare NCCI database updates before you bill.

If you perform an evaluation (97161) and also provide 15 minutes of therapeutic exercise (97110) on the same day, you bill both. The 97110 is subject to the 8-minute rule, but the evaluation time is excluded from that math.

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