Shelly Mesure, MS, OTR/L

Sorry, ladies, I didn’t mean to get your hopes up with that title. But does anyone else feel like there is a lot of ambiguity to the new G-Coding system? Well, it’s a little too early to tell for sure, but I can already see how the new G-codes will be riddled with red flags in the next few months.

I’ve been teaching my documentation course throughout many states these past few months, and I’d like to review the three most common questions that have been popping up.

Can Occupational Therapy use the cognition/memory code of G9168 – G9170?

No. Mainly because the Centers for Medicare & Medicaid Services has indicated that these are the codes for Speech Therapy, and did not include them on the PT/OT code list. While I recognize that memory and cognition are a big part of the OT scope of practice, I would try to relate the goals and G-coding to function-based areas and apply the self-care G-codes if applicable.

Can Physical Therapy and OT use the same codes at the same time?


Yes. As long as they relate to each discipline’s goals and clearly indicate a difference in the scope of practice to avoid duplication of services. Furthermore, I can see this as a potential red flag if PT is using self-care codes or OT is using the mobility codes at the same time. I can’t prove it’s a red flag yet, but it could be in the coming months.

Can assistants complete any part of the G-codes?

Maybe. In the regulations, it provides specific information on when the C-modifiers need to be updated to stay in compliance with the G-code reporting schedule. So, let’s review these scenarios.

A therapist must determine which G-code and C-modifier to use; however, in some updates, it requires the update to be given at the time the goal is met and also again when the next treatment session occurs, utilizing the new goals and G-code set.

So I think it’s possible for the assistant to document the updates to be compliant with this reporting schedule.

Let me explain my thoughts in further detail. Per the individual State practice acts, an assistant is able to determine if a goal has been met, and may continue treatment sessions focusing on other goals from the plan of care.

Therefore, for best practice, if the therapist is not due or available to complete an earlier supervisory visit, I feel the assistant should consult the therapist (by phone, email, or any other method of communication) to inform them of the patient achieving the goals outlined by the G-code set. The assistant should provide a treatment/daily note to reflect this conversation, and then provide the C-modifier on this same date to stay in compliance with these new regulations.

Furthermore, once this goal has been met, and the G-code has been closed-out, if the patient is still remaining on caseload, the very next visit will require a new G-code set and C-modifier updates. It’s NOT best practice to delay treatment. Therefore, the assistant would continue to schedule and provide therapy services as usual.

The G-codes are not meant to delay or prevent care or therapy services, but there are many wrinkles that need to be ironed out before we develop our industry standards on reporting methods and operational procedures. Otherwise, the clinical procedures and patient care should remain business as usual.


Shelly Mesure (“Measure”), MS, OTR/L, is the senior vice president of Orchestrall Rehab Solutions and owner of A Mesured Solution Inc., a rehabilitation management consultancy with clients nationwide. A former corporate and program director for major long-term care providers, she is a much sought after speaker and writer on therapy and reimbursement issues.