CMS Postural Drainage and Pulmonary Exercise Coverage Policy Updated for 2026 (NCD 17)

CMS has issued a modification to National Coverage Determination (NCD) 17, which governs Medicare coverage for postural drainage procedures and pulmonary exercises. This update clarifies the conditions under which physical therapists and respiratory therapists can provide these services across multiple care settings—and where coverage has firm limits. Billing teams managing pulmonary rehabilitation, home health, and outpatient therapy claims need to understand exactly where the coverage lines fall before submitting.

Field	Detail
Payer	CMS (Centers for Medicare & Medicaid Services)
Policy	Postural Drainage Procedures and Pulmonary Exercises
Policy Code	NCD 17
Change Type	Modified
Effective Date	2026-03-12
Impact Level	Medium
Specialties Affected	Physical Therapy, Respiratory Therapy, Pulmonology, Home Health, Skilled Nursing
Key Action	Verify that attending physician documentation explicitly identifies the required therapist type and medical necessity rationale before submitting claims across any affected care setting.

---

What CMS NCD 17 Covers: Postural Drainage and Pulmonary Exercise Under Medicare

The Centers for Medicare & Medicaid Services has long recognized that postural drainage procedures and pulmonary exercises serve a genuine clinical need—but coverage isn't automatic. The core principle of NCD 17 is that these services are covered under Medicare only when the attending physician determines, as part of a documented plan of treatment, that the patient's condition requires the specific knowledge and skills of either a physical therapist or a respiratory therapist.

In routine cases, nursing personnel can safely and effectively perform postural drainage and pulmonary exercises. Coverage under this NCD is triggered when the patient has an acute or severe pulmonary condition involving clinical complexity that elevates the level of skill required. That distinction—routine versus complex—is the fulcrum on which medical necessity, and therefore reimbursement, turns.

This is not a minor documentation preference. It is the threshold criteria. If the physician's plan of treatment doesn't reflect that clinical complexity and the rationale for requiring a licensed therapist, the claim lacks the medical necessity foundation CMS requires.

---

Coverage by Care Setting: Physical Therapist vs. Respiratory Therapist

NCD 17 draws a clear distinction between physical therapist services and respiratory therapist services—and that distinction matters enormously depending on where care is delivered.

Physical Therapist Coverage

When the attending physician determines that a physical therapist must provide postural drainage or pulmonary exercises, those services are covered as physical therapy across four settings:

• Inpatient hospital services
• Extended care services (skilled nursing facility)
• Home health services
• Outpatient physical therapy services

Physical therapy furnished in the outpatient department of a hospital falls under the outpatient physical therapy benefit—not the outpatient hospital benefit. That distinction affects how you bill and which benefit category you reference on the claim.

Respiratory Therapist Coverage

When the attending physician determines a respiratory therapist is the appropriate provider, coverage applies in these settings:

• Inpatient hospital services
• Outpatient hospital services
• Extended care services (skilled nursing facility)—provided the SNF has a transfer agreement with a hospital that supplies the respiratory therapist

This is where a significant coverage gap appears. Respiratory therapist services are explicitly not covered under the home health benefit. CMS will not pay for home visits by a respiratory therapist to perform postural drainage or pulmonary exercises. This is a hard exclusion in the policy, not a gray area.

Incident-to Coverage

Both physical therapists and respiratory therapists can provide these services incident to a physician's professional service, and those services are covered when furnished in that context. Teams billing incident-to must ensure all standard incident-to requirements are met—physician presence, direct supervision where required, and appropriate documentation of the physician's active involvement in the plan of care.

---

Benefit Categories Under NCD 17

This policy spans multiple Medicare benefit categories, which affects how claims are coded and submitted. The applicable categories include:

• Extended Care Services
• Home Health Services
• Incident to a Physician's Professional Service
• Inpatient Hospital Services
• Outpatient Physical Therapy Services

CMS notes this list may not be exhaustive. If your claim involves a benefit category not listed here, cross-reference with the Medicare Benefit Policy Manual before assuming coverage applies.

---

Affected Codes

The policy does not list specific CPT or HCPCS codes. NCD 17 operates as a coverage framework rather than a code-specific policy—it establishes the conditions under which services are covered, not a defined code set. When billing for postural drainage or pulmonary exercise services under this NCD, your team should apply the appropriate therapy procedure codes consistent with the service rendered and the benefit category being billed, ensuring the documentation supports the medical necessity criteria outlined in this NCD.

For reference, CMS directs providers to the following sections of the Medicare Benefit Policy Manual for additional guidance:

• Chapter 6, §20
• Chapter 7, §20
• Chapter 8, §50
• Chapter 15, §60.2

---

The Medical Necessity Documentation Standard That Drives This Policy

Because this NCD hinges almost entirely on physician judgment and documentation, the attending physician's plan of treatment is your claim's foundation. The physician must affirmatively determine—in writing—that the patient's pulmonary condition is acute or severe enough, and complex enough, to require a therapist's specific expertise.

Generic documentation ("patient needs respiratory therapy") will not hold up to review. The record should reflect the clinical complexity, why nursing personnel cannot safely or effectively perform the procedure, and which therapist type the physician is ordering and why.

For SNF claims involving respiratory therapists, there's an additional layer: the policy requires that the SNF have a transfer agreement with a hospital that furnishes the respiratory therapist. If that transfer agreement doesn't exist or isn't documented in the facility's records, coverage for those services is at risk.

---

What Your Billing Team Should Do

Copy Action Items

---