Aetna modified CPB 0174 for aquatic therapy (pool therapy, hydrotherapy), effective September 26, 2025. Here's what changes for billing teams.
Aetna, a CVS Health company, updated its aquatic therapy coverage policy under CPB 0174 in the Aetna aquatic therapy coverage policy governing CPT 97113 and CPT 97036. The core rules stay intact, but this modification clarifies exactly where medical necessity ends and where maintenance therapy begins — a distinction that will drive more claim denials if your documentation doesn't hold up.
Quick-Reference Table
| Field | Detail |
|---|---|
| Payer | Aetna, a CVS Health company |
| Policy | Pool Therapy, Aquatic Therapy or Hydrotherapy |
| Policy Code | CPB 0174 Aetna |
| Change Type | Modified |
| Effective Date | September 26, 2025 |
| Impact Level | High |
| Specialties Affected | Physical therapy, occupational therapy, rehabilitation medicine, neurology, orthopedics, oncology |
| Key Action | Audit active aquatic therapy authorizations before September 26, 2025 — any maintenance-only cases will not meet medical necessity under this policy |
Aetna Aquatic Therapy Coverage Criteria and Medical Necessity Requirements 2025
The Aetna aquatic therapy coverage policy under CPB 0174 draws a hard line. Aquatic therapy is medically necessary when it treats a musculoskeletal condition and the member is making measurable functional progress.
The moment progress stops — when your patient is maintaining but not improving — Aetna calls it maintenance therapy. Maintenance therapy is not medically necessary under this policy. That's not a gray area. It's a flat exclusion.
For CPT 97113 (aquatic therapy with therapeutic exercise) and CPT 97036 (Hubbard tank, each 15 minutes), your documentation has to show active functional improvement. Subjective notes like "patient tolerating therapy well" or "continues to benefit from pool exercise" are not enough. You need objective, measurable progress documented at each visit.
This is the same framework Aetna applies to land-based therapeutic exercise. The water doesn't change the rules — it just changes the treatment setting. Your billing guidelines for aquatic therapy need to match the same documentation standards you use for CPT 97110 and similar codes.
Prior authorization requirements vary by plan. Check the member's specific Aetna plan before scheduling — some Aetna commercial plans require prior auth for physical therapy services, including aquatic therapy. Don't assume a standard commercial plan mirrors the coverage policy language. The coverage policy sets the medical necessity floor; the member's benefit design sets the access rules on top of that.
Reimbursement for CPT 97113 is billed per 15-minute unit. Document your time precisely. Aetna auditors will look at whether the number of billed units matches the clinical record.
Aetna Aquatic Therapy Exclusions and Non-Covered Indications
Maintenance therapy is the primary exclusion here. Aetna defines maintenance therapy as treatment carried out only to maintain the member's current level of function — meaning neither improving nor regressing.
This matters most in two scenarios your billing team sees regularly.
First, chronic condition management. Patients with Parkinson's disease (G20.A1–G20.C), Alzheimer's disease (G30.0–G30.9), or other progressive neurological conditions often plateau. Once they plateau, continued aquatic therapy is maintenance — and Aetna will deny it.
Second, post-surgical rehab late in the episode of care. A patient six months out from a total knee replacement may still feel better in the pool, but if range of motion and functional scores have stabilized, you're billing maintenance therapy. That's a claim denial waiting to happen.
The real issue here is that maintenance therapy denials are often retroactive. Aetna reviews the full episode, not just the most recent dates of service. If your documentation shows plateau at visit 12 but you billed through visit 24, expect a demand for repayment on visits 12 through 24.
Document functional status at every visit. Use objective measures — FIM scores, Timed Up and Go, grip strength, range of motion in degrees — not narrative descriptions.
Coverage Indications at a Glance
| Indication | Status | Relevant Codes | Notes |
|---|---|---|---|
| Aquatic therapy for musculoskeletal conditions with documented functional improvement | Covered | CPT 97113, CPT 97036 | Objective progress required at each visit |
| Hubbard tank therapy for covered musculoskeletal conditions | Covered | CPT 97036 | Billed per 15-minute unit |
| Aquatic therapy for maintenance of current function (no improvement or regression) | Not Covered | CPT 97113, CPT 97036 | Flat exclusion regardless of diagnosis |
| Whirlpool therapy | Related — check plan benefits | CPT 97022 | Listed as a related code; coverage depends on indication and plan |
| Massage (effleurage, petrissage) | Related — check plan benefits | CPT 97124 | Related to CPB 0174 but not primary aquatic therapy codes |
Aetna Aquatic Therapy Billing Guidelines and Action Items 2025
| # | Action Item |
|---|---|
| 1 | Audit your active aquatic therapy cases before September 26, 2025. Pull every open authorization for CPT 97113 and CPT 97036. For each case, confirm the most recent clinical documentation shows measurable functional improvement — not just maintenance of current status. |
| 2 | Set a discharge trigger for plateau cases. Work with your treating therapists now. Define what "plateau" looks like in objective terms. When a patient hits that threshold, discharge from aquatic therapy billing. Continuing to bill after plateau is the scenario this policy is designed to deny. |
| 3 | Update your charge capture templates for CPT 97113 and CPT 97036. Add a required field for the objective functional measure used at that visit. If your therapists can't populate that field, the claim shouldn't go out. |
| 4 | Check prior authorization requirements by plan before scheduling. Call or check the Aetna provider portal for the specific member's plan. Some Aetna commercial plans require prior auth for therapy services. The CPB 0174 coverage policy sets the medical necessity standard, but prior authorization is a separate step that some plans require on top of it. |
| 5 | Train your documentation team on the musculoskeletal condition requirement. CPB 0174 covers aquatic therapy for musculoskeletal conditions. The ICD-10 list under this policy is broad — it includes neoplasms (C00.0–D49.9), stroke sequelae (I69.10–I69.398), Parkinson's disease, sickle cell disorders (D57.00–D57.819), and more. But every covered diagnosis still requires documented functional improvement. Diagnosis alone doesn't satisfy medical necessity. |
| 6 | Brief your compliance officer on the maintenance therapy risk. If you have patients with progressive neurological conditions — Parkinson's, Alzheimer's, dementia — who've been receiving long-term aquatic therapy, pull those charts now. If documentation shows plateau, those claims are vulnerable. Talk to your compliance officer before the September 26 effective date. |
| Previous Version | Current Version |
|---|---|
| Coverage is considered experimental and investigational for all indications | Coverage is considered medically necessary when specific criteria are met |
| Prior authorization is not required | Prior authorization is required for initial treatment |
| Documentation must include clinical history | Documentation must include clinical history |
| Re-review every 24 months | Re-review every 12 months with updated clinical documentation |
CPT, HCPCS, and ICD-10 Codes for Aquatic Therapy Under CPB 0174
Covered CPT Codes (When Selection Criteria Are Met)
| Code | Type | Description |
|---|---|---|
| 97113 | CPT | Therapeutic procedure, one or more areas, each 15 minutes; aquatic therapy with therapeutic exercise |
| 97036 | CPT | Application of a modality to one or more areas; Hubbard tank, each 15 minutes |
Other CPT Codes Related to CPB 0174
These codes are referenced in the policy but are not listed as covered under CPT 97113/97036 criteria. Coverage for these depends on the individual plan and indication.
| Code | Type | Description |
|---|---|---|
| 97022 | CPT | Application of a modality to 1 or more areas; whirlpool |
| 97124 | CPT | Therapeutic procedure, 1 or more areas, each 15 minutes; massage, including effleurage, petrissage |
Key ICD-10-CM Diagnosis Codes
CPB 0174 references 123 ICD-10-CM codes. The full list is below. Every diagnosis listed still requires documented functional improvement to satisfy medical necessity.
| Code Range / Code | Description |
|---|---|
| C00.0 – D49.9 | Neoplasms |
| D57.00 – D57.819 | Sickle cell disorders |
| F02.A0 | Dementia in other diseases classified elsewhere |
| F02.B0 | Dementia in other diseases classified elsewhere |
| F02.C0 | Dementia in other diseases classified elsewhere |
| F02.C11 | Dementia in other diseases classified elsewhere |
| F02.C18 | Dementia in other diseases classified elsewhere |
| F02.C2 | Dementia in other diseases classified elsewhere |
| F02.C3 | Dementia in other diseases classified elsewhere |
| F02.C4 | Dementia in other diseases classified elsewhere |
| F03.A0 | Unspecified dementia |
| F03.B0 | Unspecified dementia |
| F03.C0 | Unspecified dementia |
| F03.C11 | Unspecified dementia |
| F03.C18 | Unspecified dementia |
| F03.C2 | Unspecified dementia |
| F03.C3 | Unspecified dementia |
| F03.C4 | Unspecified dementia |
| F82 | Specific developmental disorder of motor function |
| G20.A1 – G20.C | Parkinson's disease |
| G21.0 | Secondary parkinsonism |
| G21.1 | Secondary parkinsonism |
| G21.2 | Secondary parkinsonism |
| G21.3 | Secondary parkinsonism |
| G21.4 | Secondary parkinsonism |
| G21.5 | Secondary parkinsonism |
| G21.6 | Secondary parkinsonism |
| G21.7 | Secondary parkinsonism |
| G21.8 | Secondary parkinsonism |
| G21.9 | Secondary parkinsonism |
| G30.0 | Alzheimer's disease |
| G30.1 | Alzheimer's disease |
| G30.2 | Alzheimer's disease |
| G30.3 | Alzheimer's disease |
| G30.4 | Alzheimer's disease |
| G30.5 | Alzheimer's disease |
| G30.6 | Alzheimer's disease |
| G30.7 | Alzheimer's disease |
| G30.8 | Alzheimer's disease |
| G30.9 | Alzheimer's disease |
| G89.0 | Central pain syndrome (post-stroke pain) |
| I61.0 | Nontraumatic intracerebral hemorrhage |
| I61.1 | Nontraumatic intracerebral hemorrhage |
| I61.2 | Nontraumatic intracerebral hemorrhage |
| I61.3 | Nontraumatic intracerebral hemorrhage |
| I61.4 | Nontraumatic intracerebral hemorrhage |
| I61.5 | Nontraumatic intracerebral hemorrhage |
| I61.6 | Nontraumatic intracerebral hemorrhage |
| I61.7 | Nontraumatic intracerebral hemorrhage |
| I61.8 | Nontraumatic intracerebral hemorrhage |
| I61.9 | Nontraumatic intracerebral hemorrhage |
| I63.0 | Cerebral infarction |
| I63.1 | Cerebral infarction |
| I63.2 | Cerebral infarction |
| I63.3 | Cerebral infarction |
| I63.4 | Cerebral infarction |
| I63.5 | Cerebral infarction |
| I63.6 | Cerebral infarction |
| I63.7 | Cerebral infarction |
| I63.8 | Cerebral infarction |
| I63.9 | Cerebral infarction |
| I69.10 – I69.198 | Sequelae of nontraumatic intracerebral hemorrhage |
| I69.20 – I69.298 | Sequelae of other nontraumatic intracranial hemorrhage |
| I69.30 – I69.398 | Sequelae of cerebral infarction |
| I73.0 | Raynaud's syndrome |
| I73.1 | Raynaud's syndrome |
| I73.9 | Peripheral vascular disease, unspecified |
| I89.0 | Lymphedema, not elsewhere classified |
| J40 – J47.9 | Chronic lower respiratory diseases |
| L20.0 | Atopic dermatitis |
| L20.1 | Atopic dermatitis |
| L20.2 | Atopic dermatitis |
| L20.3 | Atopic dermatitis |
| L20.4 | Atopic dermatitis |
| L20.5 | Atopic dermatitis |
| L20.6 | Atopic dermatitis |
The policy references 43 additional ICD-10-CM codes not fully listed in the extracted data above. Access the full code list at the CPB 0174 Aetna policy source.
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