Chiropractic documentation gap analysis

Recognize what’s missing to master your reimbursement and collections!

This Documentation Gap Analysis allows us to evaluate the significant components of your current Documentation program. It should take less than 5 minutes to complete.

Take The Billing GAP Analysis

Need more guided help? Work with a KMC coach 1-on-1

Sometimes you need more than a self-service, on-demand program and need an expert to analyze your issues, train the corrections, and help you implement the changes, so they stick

Learn More
Dr Alan Sokoloff 1

New Course Available!

This course explains the significant role chiropractic care can play in the sports industry and how a DC can succeed as a Sports Chiropractor. Start your steps to success here!

Learn More

There's no need to fear the OIG. We've got your back!

The most effective chiropractic OIG compliance programs are scaled according to the size of the practice!

Learn More

KMC University on 97140, Manual Therapy

97140, manual therapy, is one of the most confusing codes in the typical chiropractor’s coding arsenal

Here are some details you should be aware of when billing this code:

Coding Chiropractic Services


97140 is described by the AMA as “manual therapy, one or more regions, each 15 minutes.” This is a constant attendance therapeutic procedure code.


Manual therapy techniques consist of, but are not limited to, soft tissue and joint mobilization, manipulation, manual lymphatic drainage, manual traction, non-injectable trigger point therapy, and myofascial release. When performing manual therapy, make sure that you’re performing this service to a separate anatomic region than you are performing a chiropractic manipulative treatment. Your treatment should be performed based on function-based goals of improved and pain-free range of motion, as well as a patient’s return to activities that he/she currently is unable to do.


Ensure that your exam and documentation indicates a subjective loss of mobility, loss of strength or joint motion, pain, soft tissue swelling, inflammation or restriction, etc. to warrant this service.

Treatment Plan

Your treatment plan should indicate a direct functional goal or outcome from performing this service. An example of a direct functional goal would be “able to bend over to tie shoes by himself within two weeks.”


The National Correct Coding Initiative (NCCI) edits created by the Centers for Medicare and Medicaid Services (CMS) require that manual therapy techniques be performed in a separate anatomic site than the chiropractic adjustment in order to be reimbursed. Depending on the carrier, when billing procedure code 97140 you must append a modifier. With most payers the -59 modifier is the most widely accepted modifier to signify that a separate and distinct service was performed in a separate anatomic site. CMS has established the following four HCPCS modifiers (referred to collectively as –X{EPSU} modifiers) to define specific subsets of the -59 modifier: XE Separate Encounter; XS Separate Structure; XP Separate Practitioner; XU Unusual Non-Overlapping Service. Additional information can be found in the CMS Modifier 59 Article here.

Remember that 97140 is a timed code, therefore you must indicate the number of units administered to the patient. The KMC University Library has helpful Fact Sheets and Tutorials on how to properly report and code timed codes. If applicable, use diagnosis pointers in box 24E of your 1500 Claim Form to indicate which diagnosis is related to which distinct service. For example, you may point your cervical CMT code (98940) to your cervical diagnosis and your manual therapy code (97140) to your lumbar diagnosis.

Chiropractic Coding RisksReconsideration

Should a payer deny this service with a remark code that indicates 97140 was included in another service billed (98940 or 98941), we suggest you send a letter to the insurance

Based on the ACA’s (American Chiropractic Association) knowledge of the development and valuation process for CPT codes 97140 and chiropractic manipulative treatment codes, their stance is that CPT code 97140 is an independent procedure when provided to a different anatomic region than the procedure described as chiropractic manipulative treatment. When these procedures are billed together, the modifier “-59” is used to communicate that independent procedures that are not normally billed together were performed and medically necessary under the circumstances. Be sure to send your well-documented notes as well as  the information concerning the ACA’s stance on the use of code 97140.

Image Image

Thank you for the recap summary and for your wonderful insight. We're so pleased that we can call the HelpDesk and speak to such knowledgeable responders such as yourself!  We've been so grateful for you guys.

Dr. Crystal Nix