Pulmonary rehabilitation (PR) has experienced some changes in 2022 including new codes. By gaining better comprehension of this service, RT healthcare coding and billing professionals can help ensure accurate coding while safeguarding full reimbursement. Let’s take a look at some of the details and changes that will impact your coding and billing.
Understand that historically and until December 31, 2021, PR services completed as a part of a comprehensive PR program benefit, were reported using HCPCS Level II code G0424:
| G0424 | Pulmonary rehabilitation, including exercise (includes monitoring), one hour, per session, up to two sessions per day. |
2022 saw the arrival of two brand new codes for reporting these services. The codes are differentiated by the need for continuous oximetry monitoring:
| 94625 | Physician or other qualified health care professional services for outpatient Pulmonary rehabilitation; without continuous oximetry monitoring (per session)
Revenue Code: 0948 |
| 94626 | Physician or other qualified health care professional services for outpatient pulmonary rehabilitation; with continuous oximetry monitoring (per session)
Revenue Code: 0948 |
So, what APC have these new codes been assigned to? Both codes are assigned to APC 5733 (Level 3 Minor Procedures). This is the same APC to which G0424 had been assigned previously—in the 2022 OPPS final rule, with a simulated “per-session” median cost of approximately $56.85 for 2022.
With new codes many coders may wonder what exactly are the billing requirements for these codes and are there any special areas of concern? Understand that in the hospital outpatient setting, payment for PR services will be set by establishing a clinical APC with a median “per session” cost, simulated from historical claims data for similar pulmonary therapy services. Note that Physical therapists cannot bill PT codes separately if they conduct assessments and individual treatment services as part of a PR program. Know that the PT services are now included as part of the overall treatment plan for PR and must be billed using the new CPT® codes 94625–94626 for 2022.
The pandemic created some noteworthy changes to direct supervision requirements that may prove to be confusing, however it is important to understand the circumstances beforehand. Prior to the COVID-19 Public Health Emergency (PHE), CMS rules have traditionally stated that non-physician practitioners, (physician assistants, nurse practitioners, and others) are not permitted to provide “direct supervision” under the PR program in either the physician office or hospital outpatient setting. This also applied to cardiac rehabilitation (CR) and intensive cardiac rehabilitation (ICR). CMS maintained that the law is very specific in using the term “physician” for supervised programs, and that there was no flexibility in expanding the definition to include non-physician practitioners.
Understand that “Direct supervision” by definition required the physician to be “present on the same campus and immediately available to furnish assistance and direction throughout the performance of the procedure.”
For hospitals or CAHs, the “geography” of direct supervision has historically applied to:
Note that the direct supervision requirement waiver for small rural PPS hospitals (100 beds or fewer) and CAHs initially expired on December 31, 2014, and again, December 31, 2016.
However, understand that in the 2018 final rule, CMS reinstated the non-enforcement of direct supervision requirements for outpatient therapeutic services for CAHs and small rural hospitals having 100 or fewer beds for the next two years—2018 and 2019. During the 2020 final rulemaking, CMS finalized a change to the generally applicable minimum supervision level from direct supervision to general supervision.
It is important to know that under general supervision “the procedure is furnished under the physician’s overall direction, but the physician’s presence is not required during the performance of the procedure.” In addition, beginning in 2014, payment for “incident to” hospital or CAH outpatient services (sometimes referred to as hospital or CAH “therapeutic” services) was amended to explicitly require that individuals furnishing these services be in compliance with state law.
Therefore, hospitals and CAHs are encouraged to continue using the APC Advisory Panel process established in 2012 to request changes they believe would be appropriate in supervision levels for individual hospital outpatient therapeutic services. This is especially true for those that have not yet been evaluated by the panel including:
In 2020 and continuing into 2022, as a result of the COVID-19 PHE, additional waivers were granted. The definition of direct supervision was updated to include, during the PHE, a virtual presence through the use of interactive telecommunications technology, for services paid under the Medicare Physician Fee Schedule as well as for hospital outpatient services. This includes:
Moreover, direct supervision requirements were relaxed to allow general supervision throughout hospital outpatient non-surgical extended duration therapeutic services. General supervision may also include a virtual presence through the use of telecommunications technology as well as audio-only. Being mindful of these changes and others are key to encouraging success throughout the year for RT coding and billing.
Explore more billing tips and insight for respiratory CPT coding by ordering our Coding Essentials for RT/Pulmonary Function resource.
Combat is often described as hours of boredom intermixed with moments of sheer terror. I fear that that metaphor is increasingly applicable to Medicare enrollment. Few
Let’s start with a recent (U.S. Department of Health and Human Services Office of Inspector General) OIG audit of a Medicare Advantage plan. Now these
Please log in to your account to comment on this article.
Gain clarity and confidence in OB‑GYN coding with this expert‑led webcast featuring Stacey Shillito, CDIP, CPMA, CCS, CCS‑P, CPEDC, COPC. You’ll learn how to apply global maternity package rules accurately, select the right CPT codes for procedures and visits, and identify documentation gaps that lead to denials. With practical guidance and real examples, this session helps you strengthen compliance, reduce audit risk, and ensure accurate reimbursement for women’s health services.
Uncover essential coding insights with nationally recognized coding authority Kay Piper, RHIA, CDIP, CCS. Through ICD10monitor’s interactive, on‑demand webcast series, Kay walks you through the AHA’s 2026 ICD‑10‑CM/PCS Quarterly Coding Clinics, translating each update into practical, easy‑to‑apply guidance designed to sharpen precision, ensure compliance, and strengthen day‑to‑day decision‑making. Available shortly after each official release.
Uncover critical guidance on the ICD-10-CM/PCS code updates. Kay Piper reviews and explains ICD-10-CM/PCS coding guidelines in the AHA’s fourth quarter 2026 ICD-10-CM/PCS Coding Clinic in an easy to access on-demand webcast.
Uncover critical guidance on the ICD-10-CM/PCS code updates. Kay Piper reviews and explains ICD-10-CM/PCS coding guidelines in the AHA’s third quarter 2026 ICD-10-CM/PCS Coding Clinic in an easy to access on-demand webcast.
Federal auditors are intensifying their focus on inpatient psychiatric facilities, using advanced data analytics to spotlight outliers and pursue high‑dollar repayments. In this high‑impact webcast, Michael Calahan, PA, MBA, Compliance Officer and V.P., Hospital & Physician Compliance, breaks down what regulators are really targeting in IPF-PPS admissions, documentation, treatment and discharge planning. Attendees will learn practical steps to tighten processes, avoid common audit triggers and protect reimbursement and reduce the risk of multimillion-dollar repayment demands.
In this timely session, Stacey Shillito, CDIP, CPMA, CCS, CCS-P, CPEDC, COPC, breaks down the complexities of Medical Decision Making (MDM) documentation so providers can confidently capture the true complexity of their care. Attendees will learn practical, efficient strategies to ensure documentation aligns with current E/M guidelines, supports accurate coding, and reduces audit risk, all without adding to charting time.
Join Ronald Hirsch, MD, FACP, CHCQM for The PEPPER Returns – Risk and Opportunity at Your Fingertips, a practical webcast that demystifies the PEPPER and shows you how to turn complex claims data into actionable insights. Dr. Hirsch will explain how to interpret key measures, identify compliance risks, uncover missed revenue opportunities, and understand new updates in the PEPPER, all to help your organization stay ahead of audits and use this powerful data proactively.
Stay ahead of the 2026-2027 audit surge with “Top 10 Audit Targets for 2026-2027 for Hospitals & Physicians: Protect Your Revenue,” a high-impact webcast led by Michael Calahan, PA, MBA. This concise session gives hospitals and physicians clear insight into the most likely federal audit targets, such as E/M services, split/shared and critical care, observation and admissions, device credits, and Two-Midnight Rule changes, and shows how to tighten documentation, coding, and internal processes to reduce denials, recoupments, and penalties. Attendees walk away with practical best practices to protect revenue, strengthen compliance, and better prepare their teams for inevitable audits.
BLOOM INTO SAVINGS! Get 25% OFF during our spring sale through March 27. Use code SPRING26 at checkout to claim this offer.
CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 1 with code CYBER25
CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 2 with code CYBER24
