Range of Motion Testing - (CPG146) | CIGNA Coverage Update

TL;DR: Cigna Healthcare modified CPG146 (cpg146_man_musc_tstg_rom) governing range of motion testing under CPT 95851 and 95852, effective 2025-09-26. Here's what changes for billing teams.

Cigna Healthcare updated its range of motion testing coverage policy under policy code CPG146, with an effective date of September 26, 2025. The policy directly affects CPT 95851 (ROM measurements, each extremity excluding hand) and CPT 95852 (ROM measurements, hand). If your practice bills these codes alongside E/M services or therapy evaluations, this policy draws a hard line on when standalone ROM testing is — and isn't — separately billable.

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Quick-Reference Table

Field	Detail Copy
Payer	Cigna Healthcare
Policy	Range of Motion Testing (CPG146)
Policy Code	cpg146_man_musc_tstg_rom
Change Type	Modified
Effective Date	2025-09-26
Impact Level	High
Specialties Affected	Physical therapy, occupational therapy, physiatry, orthopedics, neurology, spine care
Key Action	Audit all claims pairing CPT 95851/95852 with E/M or therapy eval codes — most will not survive scrutiny under this policy

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Cigna Range of Motion Testing Coverage Criteria and Medical Necessity Requirements 2025

The central issue with the Cigna range of motion testing coverage policy is simple: for most patients, ROM testing is already included in what you're billing. Cigna's position is that routine ROM measurement is bundled into E/M services, physical therapy evaluations and reevaluations (CPT 97161–97163, 97164), and occupational therapy evaluations and reevaluations (CPT 97165–97167, 97168).

That's not a new idea — it's consistent with how CMS has treated these services. But the specificity in CPG146 puts Cigna range of motion billing under a tighter lens than many billing teams realize.

When CPT 95851 and 95852 Can Be Billed Separately

Cigna allows CPT 95851 and 95852 as separately reimbursable procedures only under narrow conditions. The policy identifies two distinct thresholds you need to clear.

First: The test must be truly separate from the evaluation or reevaluation. Baseline ROM measurements at an initial evaluation are considered incidental and included in that visit. They do not support a separate 95851 or 95852 claim. The same applies to ROM assessments performed during ongoing therapy treatment — those are bundled into the treatment service itself.

Second: The clinical situation must warrant it. Cigna's medical necessity standard for standalone ROM testing requires patients with complicated conditions who need specialized testing with standardized reports. The policy gives a concrete example: a patient with incomplete C5 quadriplegia at six months post-injury who needs specialized ROM testing to address specific deficits and goals. That's the bar. A routine orthopedic patient with shoulder pain does not meet it.

What the Written Report Requirement Actually Means

CPT 95851 and 95852 are designated as separate procedures under AMA guidelines — which means each requires a separate, distinct, dated, and signed written report reflecting the practitioner's interpretation of results. This isn't documentation for the sake of documentation. Without that standalone report, the claim has no defense in an audit.

If your team is generating ROM measurements as part of therapy notes and billing 95851 or 95852 separately without a distinct signed report, that's a claim denial waiting to happen. Pull a sample of recent claims and check whether the reports exist as separate documents.

Who Can Perform and Bill These Tests

Cigna specifies that ROM assessments should be provided by therapists or physician/non-physician practitioners (NPPs), including physician assistants, nurse practitioners, and clinical nurse specialists. The assessment must include objective testing and measurement for clinical decision-making about the patient's condition and next steps in the treatment plan.

This matters for billing because the rendering provider type affects which code set applies and whether the prior authorization requirements of the specific plan kick in. Check your payer contracts — some Cigna plan types layer additional prior auth rules on top of CPG146.

The Bundling Problem Most Billing Teams Miss

Here's where revenue cycle teams routinely get burned. The policy explicitly states that assessments — separate from evaluations and reevaluations — are included in therapy treatment services. In other words, if a therapist performs ROM measurement mid-treatment to determine the next intervention, that's billable under the treatment code, not under 95851 or 95852.

The structure looks like this:

Only that last scenario supports separate reimbursement for CPT 95851 or 95852.

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Coverage Indications at a Glance

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Cigna Range of Motion Testing Billing Guidelines and Action Items 2025

The effective date of September 26, 2025 is close. These are the actions your billing team needs to take now — not after the first round of denials comes back.

Copy Action Items

The real issue here is that range of motion billing is one of those areas where sloppy habits build up over years — therapists check a box, coders add a code, no one questions it. Cigna's updated CPG146 is a direct challenge to that pattern. The practices that get hit hardest will be the ones that didn't audit before September 26, 2025.

If your practice has high volume in physical therapy, occupational therapy, or outpatient neuro rehab and you're not sure how your current billing patterns map to CPG146, talk to your compliance officer or billing consultant before the effective date.

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CPT, HCPCS, and ICD-10 Codes for Range of Motion Testing Under CPG146

Covered CPT Codes (When Medical Necessity Criteria Are Met)

Code	Type	Description Copy
95851	CPT	Range of motion measurements and report (separate procedure); each extremity (excluding hand) or each trunk section (spine)
95852	CPT	Range of motion measurements and report (separate procedure); hand, with or without comparison with normal side

Both codes require a separate, distinct, dated, and signed written report with practitioner interpretation. Medical necessity must be documented — complicated patient conditions, specialized testing requirements, and standardized reporting are the standard Cigna applies.

Related Evaluation and Therapy Codes (Bundling Reference)

These codes bundle ROM measurement for typical patients. Billing 95851 or 95852 alongside these codes requires documented clinical justification under CPG146.

Note: The above therapy and E/M codes are referenced in the CPG146 policy summary as codes that bundle ROM measurement for typical patients. They are not designated covered or excluded codes under CPG146 — they define where 95851/95852 cannot be separately billed.

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