97161-97163 CPT Codes: PT Evaluation Complexity Tiers

Last Updated: October 23, 2025

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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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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.

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Untimed Codes

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

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NCCI Edits

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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