On March 24, 2018, the Office of Inspector General (OIG) for Center for Medicare Services (CMS) busted physical therapists for $367 million in Medicare overpayments. Medicare conducted a stratified random sample of 300 claims and found 184 of them did not comply with Medicare requirements.
OIG is establishing mechanisms to better monitor the appropriateness of outpatient Physical Therapy (PT) services and is educating providers about Medicare requirements for submitting outpatient PT claims for reimbursement. Additionally, Medicare is instructing its various contractors to notify individual Physical Therapists of potential overpayments.
Let's get to the elephant in the room. It is against the law to bill Medicare under any CPT code for physical therapy services such as Dry Needling (DN). More specifically, in States where Dry Needling is legal, there is no CPT code for dry needling. You cannot disguise DN by using the 97140 CPT code, nor by using any other CPT codes. Doing so will subject you to investigation by the Office of Inspector General Office. The OIG is informed of dry needling fraud in various states in America. The agency has already busted several PT groups for illegal CPT coding or false documentation when DN is used.
If you took an educational course on dry needling, I tell my clients to ignore any advice those courses may teach about DN CPT coding. Govern yourselves accordingly.