CPT 97750: Billing the Physical Performance Test

Medicare pays $33.73 per 15-minute unit of CPT 97750 nationally, before geographic adjustment. The Medically Unlikely Edit caps the code at 8 units per date of service. The National Correct Coding Initiative’s practitioner file pairs 97750 against the PT and OT evaluation codes (97161 through 97168) with modifier indicator 0, meaning no modifier reopens that edit on a professional claim.

Those three numbers explain most of what goes wrong with 97750: units billed past the MUE, an evaluation and a performance test denied together, or a functional capacity evaluation billed to Medicare when it belongs to an employer or workers’ compensation carrier. This guide works from the CMS 2026 RVU file, the Medicare Claims Processing and Benefit Policy Manuals, the NCCI Policy Manual and the Q4 2026 edit and MUE files, a MAC billing article, the Medicare exclusion regulations, and one state workers’ compensation fee schedule as a worked example. Current as of October 2026.

What CPT 97750 is, and how the 15-minute units work

The full descriptor, as printed by CMS in the CY 2021 PFS final rule: “97750 (Physical performance test or measurement (eg, musculoskeletal, functional capacity), with written report, each 15 minutes).”

97750 is a timed code. Under the Medicare Claims Processing Manual, Chapter 5, §20.2, timed procedure codes are billed “using CPT codes and the appropriate number of 15 minute units of service,” based on total direct one-on-one minutes for the day:

The pattern continues past 2 hours, and when more than one timed service is furnished the same day, total timed minutes across all of them determine total units. Full mechanics of rounding and mixed-code days are in our 8-minute rule guide.

Evaluation time does not count toward this chart. Chapter 15, §220.3 is explicit: “Evaluation minutes are untimed and are part of the total treatment minutes, but minutes of evaluation shall not be included in the minutes for timed codes reported in the treatment notes.”

How much Medicare pays for 97750 in 2026

From the CMS 2026 National Physician Fee Schedule Relative Value File (RVU26D, released 08/26/2026), the PFS relative value files page, and the CY 2026 conversion factor of 33.4009:

These figures are national and unadjusted: before the geographic practice cost indices, before the therapy multiple procedure payment reduction (MPPR), and before sequestration.

97750 carries Multiple Procedure indicator 5, so the MPPR applies: every unit after the highest-ranked one that day is paid with its practice expense cut in half, or 0.735 RVU ($24.55) per unit. A standalone 4-unit day totals $107.38 (versus $134.94 with no MPPR), and a standalone 8-unit day totals $205.58 (versus $269.88). The MPPR ranks every therapy unit furnished that day together, so when 97750 is billed alongside treatment codes the full-rate unit may be a different code. Our MPPR guide shows the ranking.

97750 is also disposition 5, “always therapy,” per the CY 2026 Therapy Code List and Dispositions file: it always requires the GP, GO, or GN modifier and accrues toward the $2,480 CY 2026 KX threshold. See our KX threshold guide for accrual mechanics.

If a PTA or OTA furnishes more than 10 percent of a 97750 unit, that unit takes CQ or CO and pays at 85 percent, the same rule as any other timed code. See our CQ/CO modifier guide.

Can you bill 97750 with an evaluation on the same day?

The NCCI Policy Manual, Chapter XI, §P.8 states that 97750 (with 97755 and 97763) “are not separately reportable for the same date of service with a physical therapy evaluation/re-evaluation CPT code (e.g., 97161-97164) or occupational therapy evaluation/re-evaluation CPT code (e.g., 97165-97168) when the 2 services are performed by a single practitioner or 2 practitioners of the same specialty. If the 2 services are performed by 2 different practitioners of different specialties, the 2 services may be reported using an NCCI PTP-associated modifier.”

What the edit files actually do with that rule differs by claim type:

The history in the file matters for old claims: the 97161-97168 pairs first appeared January 1, 2017, always at indicator 0 (the predecessor pairs with 97001-97004 ran from 1999 through 2016), there was no edit at all for dates of service January 1 through September 30, 2020, and the edit was reinstated October 1, 2020. MAC article A56566 confirms the result: “Do not bill test and measurement, range of motion (ROM) or manual muscle testing (MMT) codes (CPT 95851-95852, 97750, 97755) on the same day as the initial evaluation. The procedures performed are included in the initial evaluation codes and are not allowed by the Correct Coding Initiative(CCI) edits.”

The manual’s different-specialty carve-out (a PT evaluation alongside an OT-performed 97750) has no mechanical path on the practitioner file: indicator 0 blocks every modifier regardless of who performed what. The carve-out only works on the hospital file’s indicator 1. A private practice billing a professional claim gets indicator 0. Our NCCI edits guide covers the practitioner-versus-hospital distinction across the other therapy pairs.

Other 97750 edits worth knowing

From the same practitioner PTP file (v323r0, effective 10/01/2020 unless noted):

For the 97140 and 97530 pairs, the governing rule is the NCCI’s fifteen-minute principle in Chapter XI, §P.2: “providers/suppliers shall not report more than one physical medicine and rehabilitation therapy service for the same fifteen-minute time period,” and edits between timed codes “may be bypassed with modifier 59 or XU if the 2 procedures of a code pair edit are performed in different timed intervals even if sequential during the same patient encounter.” The record has to show two distinct time blocks. NCCI Chapter I covers the alternative: “A modifier shall not be appended to a HCPCS/CPT code solely to bypass an NCCI PTP edit if the clinical circumstances do not justify its use.”

The MUE: 8 units per date of service

The Q4 2026 Practitioner Services and Facility Outpatient Hospital Services MUE tables (effective October 1, 2026) both set 97750 at 8 units, with MUE Adjudication Indicator 3 (“Date of Service Edit: Clinical”), per the NCCI MUE page. For comparison, from the practitioner table:

Eight units corresponds to 113 through 127 minutes of direct testing on the unit chart above. Under NCCI Chapter I, an MAI of 3 is a date-of-service edit: “all UOS on each claim line for the same date of service for the same HCPCS/CPT code are summed, and the sum is compared to the MUE value. If the summed UOS exceed the MUE value, all UOS for the HCPCS/CPT code for that date of service are denied.” Splitting a 10-unit day across two claim lines does not help; the edit sums every line before comparing to 8. An MAI of 3 is a clinical benchmark rather than an absolute limit: a contractor “may bypass the MUE” on reopening, redetermination, or appeal when records show the units were actually furnished, correctly coded, and medically necessary. The denial is a coding denial, not a medical-necessity denial, so “the presence of an Advanced Beneficiary Notice of Noncoverage (ABN) shall not shift liability to the beneficiary for UOS denied based on an MUE.”

What the written report has to contain

The descriptor itself requires “with written report.” CMS publishes no mandated template, but Chapter 15’s documentation standard and MAC review guidance point to what a defensible report includes:

• The reason the test was ordered and the question it answers, so the record shows the services planned “are appropriate for the individual.”
• The tests performed, the protocol, and minutes of direct one-on-one time, since 97750 is timed and its units depend on documented minutes.
• Objective results for each test performed.
• The clinician’s interpretation, not just a list of numbers. Only a clinician performs an evaluation or re-evaluation, and a clinician “may not merely summarize the objective findings of others or make judgments drawn from the measurements and/or observations of others.”
• How the results change the plan of care, goals, or return-to-work status.
• Clinician signature and date.

A report that lists numbers without interpretation or a stated effect on the plan of care does not satisfy the descriptor, regardless of units billed.

97750 versus a re-evaluation versus routine measures in a treatment visit

All three involve measuring a patient. They are not interchangeable:

For more on what the underlying visit note needs to support any of these, see our documentation requirements guide.

Functional capacity evaluations: who pays, and when Medicare does not

Medicare excludes third-party exams by regulation. 42 CFR 411.15(a)(1)-(2) excludes “examinations performed for a purpose other than treatment or diagnosis of a specific illness, symptoms, complaint, or injury” and “examinations required by insurance companies, business establishments, government agencies, or other third parties.” An FCE for an employer, disability insurer, or workers’ compensation carrier is not Medicare-covered; 97750 under a Medicare plan of care must answer a treatment question instead, such as capacity to progress or safety for a specific activity.

Work injuries are separately excluded under 42 CFR 411.40(b)(1): Medicare does not pay for services “for which payment has been made, or can reasonably be expected to be made under a workers’ compensation law or plan,” a definition that covers the plans of the 50 states, the District of Columbia, and the territories, plus the federal systems under FECA and the Longshore and Harbor Workers’ Compensation Act.

State programs handle FCEs on their own terms and often skip 97750 entirely. Washington’s Department of Labor & Industries, in its 2026 Medical Aid Rules and Fee Schedules, Chapter 20 (effective July 1, 2026), requires prior authorization for FCEs and its own local codes:

Washington also requires the FCE to be performed by a physiatrist, PT, or OT, caps billing to once per worker every 30 days, and requires documented time per evaluator plus a completed capacity form. Other states set their own rules and some price 97750 differently, so read the specific program’s fee schedule before billing.

Federal workers’ compensation (FECA) prices by formula rather than by local code: under 20 CFR 10.805, payment for a CPT-coded service “shall not exceed the amount derived by multiplying the Relative Value Units (RVU) values for that procedure by the Geographic Practice Cost Index (GPCI) values for services in that area and by the conversion factor,” using the RVUs CMS publishes and a conversion factor OWCP sets. 20 CFR 10.813 bars billing the worker for the balance. Look up OWCP’s current conversion factor before quoting a 97750 rate under FECA; the figure is not in this guide.

One more line from the practitioner file for practices that also bill disability examinations: 99455 and 99456 sit as Column One against 97750 at indicator 0, effective October 1, 2020, so on a professional claim the performance test is not separately payable on the same date as the disability examination and no modifier changes that.

The denials billers actually see

1. 97750 with 97161-97168, same date, professional claim. The practitioner-file Column Two edit at indicator 0. Test on a different date, or bill the evaluation alone that day.
2. 97750 with 97530 or 97140, no distinct-time documentation. Both services claimed for the same 15-minute block. Document separate time blocks; append 59 or XU only when the record supports it.
3. Units above 8 on a date of service. The DOS MUE, MAI 3. Splitting units across claim lines does not avoid it; if the units were genuinely furnished and documented, appeal with records rather than relying on an ABN.
4. Missing GP or GO modifier. 97750 is “always therapy,” so the modifier is required regardless of who performs it.
5. Testing for an employer or insurer, billed to Medicare. Excluded under 411.15(a)(2), and a work injury belongs to the workers’ compensation payer under 411.40(b). Bill that payer under its own codes and fee schedule.
6. No written report, or a report that only lists numbers. Fails the descriptor’s “with written report” requirement and the reviewer’s documentation standard. Include the interpretation and the plan-of-care effect, not just raw results.

Quick answers to the edge cases

Can a PT do the evaluation and an OT perform 97750 the same day under one billing NPI? No, on a professional claim. Indicator 0 blocks every modifier regardless of specialty; the different-specialty carve-out only bypasses on the hospital file.

Can 97750 be billed with 97530 in the same visit? Yes, if furnished in genuinely distinct 15-minute blocks, documented that way, with modifier 59 or XU.

Can an FCE for an employer be billed to Medicare with an ABN? No. It’s excluded under 411.15(a)(2) regardless of an ABN; an ABN addresses medical-necessity denials, not statutory exclusions.

Can a re-evaluation be swapped in when 97750 edits against the evaluation? No. A re-evaluation is only covered when new findings or a significant change justify it, and it should not be routinely reported just to work around another code’s edit.

Can a PTA administer the test? Medicare’s rule is the modifier rule: a unit furnished more than 10 percent by an assistant takes CQ or CO and pays at 85 percent. State practice acts and payer policies may separately restrict who administers the test, and the interpretation in the written report is clinician work.

97750’s rules are three separate limits stacked on one code: an 8-unit MUE, an indicator-0 edit against the evaluation codes, and an always-therapy modifier requirement, all enforced against whatever units and codes already sit on the same date of service. PrismEHR lets organizations define their own billing rules, including minute and unit restrictions by code, enforced at documentation and reinforced again at claim creation, the kind of rule that stops 97750 from being added to a date that already carries 97161 through 97164, or caps it at 8 units per date. Units default to zero rather than prefilling from the prior visit. See how it fits physical therapy and orthopedic practices, and read our NCCI edits guide for how the practitioner and hospital PTP files differ more generally.