Surgical · Multi-region

98928

Osteopathic manipulative treatment performed by a physician (usually a DO) across 7 to 8 separate body regions during a single encounter, based on documented somatic dysfunction in each region.

3 sources ↓

Medicare
$73.48
Work RVU
1.18
Global, days
0
Region
Multi-region
Drawn from CMS

Documentation requirements

What must appear in the operative or office note to support the claim.

Source · Editorial brief grounded in 3 cited references ↓

  • Each of the 7 to 8 body regions treated, named individually (for example cervical, thoracic, lumbar, sacral, pelvic, upper extremity)
  • Somatic dysfunction findings per region: tissue texture change, asymmetry, restricted motion, or tenderness
  • Technique used in each region, such as muscle energy, counterstrain, myofascial release, or HVLA
  • Patient tolerance and response after treatment
  • Somatic dysfunction ICD-10 codes (M99.0x) that match each treated region
  • If an E/M is billed the same day, a separate history, exam, and decision-making section beyond the pre-manipulation assessment

Applicable modifiers

Modifiers commonly billed with this code.

Source · AMA CPT modifier descriptors · CMS NCCI Policy Manual

What this code covers

Source · Editorial summary grounded in 3 cited references ↓

98928 reports osteopathic manipulative treatment (OMT) when the physician treats 7 or 8 body regions in one visit. The ten recognized regions are head, cervical, thoracic, lumbar, sacral, pelvic, lower extremities, upper extremities, rib cage, and abdomen/viscera. Count regions treated, not techniques used. Three techniques on the lumbar spine is still one region.

Seven or eight regions is uncommon in an orthopedic setting and draws audit attention. It fits patients with widespread dysfunction, for example after a motor vehicle collision with neck, thoracic, rib, lumbar, sacral, pelvic, and extremity complaints. If the note reads like a template, expect a records request.

Expect the E/M on the same date to get a second look. Modifier 25 is correct only when the note shows real evaluation work beyond picking regions to treat. The code has a 0-day global, so follow-up visits are billed on their own merits.

RVU & reimbursement

Component RVUs and Medicare national rate. Actual payment varies by GPCI locality.

Source · CMS Physician Fee Schedule, RVU26A · January 2026

Work RVU vs. total RVU

The work RVU (1.18) is the surgeon's own effort — the figure physician pay and productivity targets are built on. The total RVU (2.2) adds practice overhead and malpractice, and is what drives the Medicare payment below.

Work RVU 1.18
Practice expense RVU 0.95
Malpractice RVU 0.07
Total RVU 2.2
Medicare national rate $73.48
Global period 0 days

Payment by site of service

Medicare pays different rates by setting. HOPD typically pays substantially more than ASC for the same procedure.

Source · CMS OPPS Addendum B·ASC HCPCS payment rates·2026

SettingMedicare rate (national)
Office (PFS non-facility)
Procedure performed in physician's office
$73.48
HOPD (APC 5811)
Hospital outpatient department
$22.06

Common denial reasons

The recurring reasons claims for CPT 98928 get rejected.

Source · Editorial brief grounded in CMS NCCI edits, AAOS coding appeals, and cited references ↓

  • Region count in the note does not support the code level billed
  • M99.0x somatic dysfunction codes missing or not matching the treated regions
  • E/M billed same day without modifier 25 or without separately documented work
  • Rendering provider is not credentialed for OMT under that payer contract
  • Payer visit limits for manual therapy already reached for the benefit year

Frequently asked questions

Source · Generated from the editorial pipeline, verified against 3 cited references ↓

01When is CPT 98928 used?
98928 is used when a DO treats seven or eight body regions with OMT in one visit. Each region needs its own documented findings and treatment.
02Does Medicare cover 98928?
Yes, Medicare pays 98928 when it is medically necessary and supported by somatic dysfunction findings in seven or eight regions.
03Can a chiropractor bill 98928?
No. Chiropractors report chiropractic manipulation with 98940 to 98943. The 98925 to 98929 range is for osteopathic treatment.
04Why do payers audit 98928 so often?
High region counts are rare, so cloned notes stand out. Payers look for region-specific findings that change from visit to visit.

Sources & references

Editorial content was developed using the following public sources.

  1. 01CMS Physician Fee Schedule 2026
  2. 02
    cms.gov
    https://www.cms.gov/medicare/payment/fee-schedules/physician
  3. 03
    cms.gov
    https://www.cms.gov/medicare/coding-billing/national-correct-coding-initiative-ncci-edits

Mira Scribe

Mira Scribe lists each treated region with its findings and technique, so the note clearly supports 7 to 8 regions. When the visit also covers a separate problem, that work lands in its own section to back up modifier 25.

See how Mira captures CPT 98928 documentation

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