What is moderate complexity physical therapy evaluation?
CPT code 97162 is used to report a moderate complexity physical therapy evaluation performed by licensed physical therapists. This evaluation applies when a patient’s clinical presentation is moderately complex and cannot be sufficiently addressed by a low complexity evaluation (97161), but does not meet the threshold for a high complexity evaluation (97163).
A moderate complexity evaluation typically involves:
- A medical history with one or more personal factors or comorbidities that may affect treatment
- An examination of body systems related to the patient’s condition—such as the musculoskeletal system, neuromuscular system, and cardiovascular system
- Identification of three or more performance deficits in areas such as balance, mobility, muscle strength, or coordination
- Use of standardized tests or standardized patient assessment instruments to establish functional status and clinical findings
- Moderate clinical decision making that considers variable patient's clinical presentation, patient's personal factors, and expected progression
This evaluation process helps physical therapists develop a personalized physical therapy established plan that includes clear treatment plans, measurable assessments, and anticipated outcomes.
Evaluation complexity and its impact on the billing process
When assigning CPT code 97162, it's essential to understand how evaluation complexity influences both the comprehensive assessment and the overall billing process. Evaluation complexity refers to the level of detail, clinical judgment, and problem-solving required by the physical therapist during the patient assessment.
While therapeutic exercises are commonly part of a treatment plan, they do not factor into determining the evaluation code itself. Instead, it's the depth of assessment—including medical and therapy history, the number of performance deficits, and decision-making requirements—that define whether an evaluation is low, moderate, or high in complexity.
A high complexity history, for example, involves extensive comorbidities or multiple prior interventions and is more aligned with CPT code 97163. In contrast, CPT 97162 is appropriate when the patient’s history is moderately detailed but still significantly impacts care planning.
Thoroughly documenting the comprehensive assessment, including medical history and performance limitations, helps justify the complexity level selected and streamlines the billing process. Clear classification of complexity also reduces the risk of upcoding, underbilling, or payment delays.






