Which Code Is CPT 98941 and When Do You Report It
The 98941 CPT code description covers chiropractic manipulative treatment (CMT) of the spine across three to four spinal regions. You report it when a Doctor of Chiropractic adjusts three or four of the five recognized spinal regions in a single visit. The region count, not the number of adjustments, sets the code.
The code isn’t location-specific. CPT 98941 applies in an office (POS 11) and in a federally qualified health center (POS 50). What drives the code is documentation of three or four spinal regions treated, not where the patient got the adjustment.
CMS recognizes five spinal regions for CMT coding: cervical, thoracic, lumbar, sacral, and pelvic. Your note and claim have to name the specific vertebral levels in each region, not the region alone. CMS Article A56273 requires the precise level of the subluxation on the claim.
| Spinal Region | Vertebral Levels Included | Primary ICD-10 |
|---|---|---|
| Cervical | C1-C7, includes the atlanto-occipital joint | M99.01 |
| Thoracic | T1-T12, includes the costovertebral joints | M99.02 |
| Lumbar | L1-L5 | M99.03 |
| Sacral | Sacrum and coccyx | M99.04 |
| Pelvic | Pelvic structures, includes the ilium | M99.05 |
The official 98941 CPT code description reads: Chiropractic manipulative treatment (CMT); Spinal, 3-4 regions.
The most common 98941 error is billing by adjustment count instead of region count. Three adjustments in the lumbar spine is one region, not three. A chiropractor who adjusts the cervical, thoracic, and lumbar regions with one adjustment each has treated three regions and reports 98941, not 98940.
Chiropractic practices that confuse region count with adjustment count over-bill and under-bill in the same week. One O Seven’s chiropractic practice billing services add a region-count check to every CMT claim before submission.
Region Decision Table: 98940 vs 98941 vs 98942 vs 98943
What is the difference between CPT code 98940 and 98941?
All three primary CMT codes describe the same service: spinal manipulation to correct a subluxation. They differ by how many spinal regions your documentation supports. The table below maps region count to the right code, the documentation it takes, and what the payer does when the code is wrong.
| Regions Treated | Correct Code | Documentation Requirement | Wrong-Code Consequence |
|---|---|---|---|
| 1 to 2 regions | CPT 98940 | Name each region with vertebral levels; document the subluxation per region | Billing 98941 for two regions is upcoding; Medicare returns CO-11 or flags an audit |
| 3 to 4 regions | CPT 98941 | Name each of the three or four regions with levels; the SOAP note supports every region | Billing 98940 for four regions underbills the visit; revenue leaks |
| 5 regions | CPT 98942 | Name all five regions; documentation supports all five; highest audit risk | Billing 98941 for five regions downcodes the visit; revenue leaks |
| Extraspinal only | CPT 98943 | Extremities, ribs, head; not spine; billed apart from CMT | Medicare doesn’t cover 98943; bill commercial payers only |
You can’t bill 98940 and 98941 on the same date of service for the same patient. Pick one code for the total regions treated that encounter. The 98941 CPT code description specifies three to four regions, so a five-region visit moves to 98942.
Medicare doesn’t reimburse CPT 98943, and commercial payers vary. When you bill 98941 and 98943 together on a commercial claim, append Modifier 59 to 98943 and point its diagnosis to the specific extraspinal site. The 98943 diagnosis can’t reuse the spinal subluxation code.
When the subluxation code lands as secondary instead of primary, Medicare returns CO-11. The CO-11 diagnosis-procedure mismatch guide walks through the exact ICD-10 correction path for CMT claims.
Medicare Coverage Rules for CPT 98941: AT Modifier, Subluxation, and Maintenance Care
Medicare Part B covers the service behind the 98941 CPT code description, but only inside one narrow benefit: manual manipulation of the spine to correct a documented subluxation, delivered as active, corrective care. Medicare doesn’t cover chiropractic E/M visits, x-rays a chiropractor orders, or extraspinal manipulation (98943).
Does 98941 need a modifier?
For Medicare claims, yes. CPT 98940, 98941, and 98942 need Modifier AT (Active Treatment) on every claim where the chiropractor delivers active or corrective care for an acute or chronic subluxation. The CMS chiropractic billing and coding article A56273 states that claims for 98941 without the AT modifier are considered not medically necessary, and Medicare denies them.
Appending AT opens the payment gate. It isn’t the compliance defense. Medicare also wants documented proof of the subluxation: an x-ray showing the misalignment, or a physical exam that meets the PART criteria.
PART stands for Pain or tenderness, Asymmetry or misalignment, Range of motion abnormality, and Tissue or tone changes. You document at least two of the four, and one has to be A or R. Without it, the AT modifier won’t stop a CO-50 denial after audit.
Medicare draws a hard line between active treatment and maintenance care, and that line decides whether 98941 pays. Active treatment improves the subluxation; the patient’s objective status changes. Maintenance care holds the condition steady. Once the patient plateaus, Medicare treats later visits as maintenance and denies them, even with AT attached.
When you plan maintenance care Medicare won’t cover and the patient wants to continue, you issue an Advance Beneficiary Notice and append Modifier GA. CMS updated the ABN, Form CMS-R-131, effective March 13, 2026. Practices using the old form after May 12, 2026 hold invalid ABNs and can’t bill the patient.
Medicare spells out the chiropractic benefit in Section 30.5 of the CMS Medicare Benefit Policy Manual Chapter 15, the controlling coverage reference for every 98941 claim.
Medicare chiropractic billing runs a 33.6% improper payment rate, the highest of any service CMS tracks. At that rate, a practice billing 98941 without a documentation and modifier review is opening compliance gaps on most of its Medicare claims.
CPT 98941 Reimbursement: 2026 Medicare Rates and Commercial Benchmarks
How much is the average reimbursement for 98941?
The 2026 Medicare national average for CPT 98941 in a non-facility setting runs approximately $38.41 per encounter. That figure tracks the 2026 CMS Physician Fee Schedule Final Rule, which set two conversion factors starting January 1, 2026: $33.57 for qualifying APM participants and $33.40 for everyone else. Your locality-adjusted rate moves with your geographic cost index.
CMS also finalized a 2.5% efficiency adjustment that trims work RVUs on many non-time-based services in 2026. Check whether 98941 sits in the affected set using the CMS PFS Addendum B file.
To run your own 2026 rate for the 98941 CPT code description: work RVU times your geographic practice cost index times the conversion factor ($33.40 for non-QP providers). Texas practices under Novitas Jurisdiction H can pull locality rates from the Novitas JH fee schedule lookup. Confirm any figure at the CMS Physician Fee Schedule lookup tool.
Commercial payers pay above Medicare for 98941. Industry benchmarks put most commercial chiropractic reimbursement between 120% and 200% of the Medicare rate, depending on your contract, your market, and your specialty. Compare your contracted rate against that range at every renewal.
Can You Bill 97140 and 98941 Together? The NCCI Same-Region Rule
Can we bill 97140 and 98941?
It depends on where you performed the 97140. Manual therapy in the same spinal region as the adjustment can’t be billed separately. Manual therapy in a different, non-contiguous region from the CMT can be billed separately with the right modifier. Region is the deciding factor.
The CMS NCCI Policy Manual (effective January 1, 2026) treats physical medicine and rehabilitation services, including CPT 97112, 97124, and 97140, as not separately reportable when they’re performed in a spinal region that’s getting chiropractic manipulative treatment. Perform them in a separate, non-contiguous region, and they can be separately reportable with Modifier 59 or Modifier XS.
When the NCCI edit fires and CO-97 hits your 97140 line, the CO-97 bundling denials guide maps the fix and the modifier-bypass call for each region combination.
Contiguous versus non-contiguous is the call that decides whether 97140 and 98941 ride the same claim. Cervical and thoracic are contiguous, so manual therapy in the thoracic region on the same day as a cervical adjustment isn’t separately billable.
Cervical and lumbar are non-contiguous. Lumbar manual therapy on a day you adjusted only cervical and thoracic is separately billable with Modifier 59 or XS on 97140.
If you’ve appended Modifier 59 to 97140 and still drew NCCI denials, the NCCI edit resolution guide covers the Correct Coding Modifier Indicator lookup that tells you whether a bypass modifier is even allowed for a code pair.
When you bill 97140 apart from 98941, the documentation has to show three things: the manual-therapy region differs from the adjusted regions, each service was medically necessary, and the 97140 ran at least eight minutes for one unit. Record start and end times or total treatment minutes per service.
For unattended electrical stimulation on the same date as 98941, Medicare doesn’t recognize CPT 97014. Bill HCPCS G0283 instead. Send 97014 to Medicare and the line draws a CO-97 denial. Resubmitting with G0283 fixes it, but timely-filing limits make catching this before submission the safer play.
ICD-10 Diagnosis Codes for CPT 98941: Primary and Secondary Hierarchy
Pairing diagnoses to the 98941 CPT code description starts with one rule: the subluxation code goes primary on every claim. The neuromusculoskeletal condition, the back pain or cervicalgia or muscle spasm, sits secondary.
List a low back pain code like M54.50 as primary and the lumbar subluxation M99.03 as secondary, and Medicare reads the claim as missing its subluxation diagnosis and denies it under CO-11.
Here are the chiropractic diagnosis codes that belong in the primary position, mapped by region:
| Spinal Region | Primary ICD-10 | ICD-10 Description | Documentation Note |
|---|---|---|---|
| Cervical | M99.01 | Segmental and somatic dysfunction, cervical region | Add the cervical level (C1-C7) |
| Thoracic | M99.02 | Segmental and somatic dysfunction, thoracic region | Add the thoracic level (T1-T12) |
| Lumbar | M99.03 | Segmental and somatic dysfunction, lumbar region | Add the lumbar level (L1-L5) |
| Sacral | M99.04 | Segmental and somatic dysfunction, sacral region | Add the sacral or coccygeal level |
| Pelvic | M99.05 | Segmental and somatic dysfunction, pelvic region | Add the ilium or SI joint |
Secondary diagnoses carry the medical necessity story. The common secondary codes on 98941 claims are M54.50 (low back pain), M54.2 (cervicalgia), M54.51 (vertebrogenic low back pain), M62.830 (muscle spasm of back), and M54.16 (lumbar radiculopathy). Match the ICD-10 codes for chiropractic care to the documented symptoms, not to habit.
Specificity holds up better under review. M54.51 (vertebrogenic low back pain) beats M54.50 (unspecified low back pain) when the documentation supports a vertebrogenic cause.
Commercial payers running Optum’s clinical edits want a subluxation diagnosis for every region billed, or validated diagnoses for two regions plus documented soft-tissue and segmental findings for the adjacent treated regions. Check your Optum-contracted payer’s chiropractic documentation policy before you bill 98941.
Documentation Requirements for CPT 98941: The Six Elements CMS Auditors Verify
Chiropractic billing carries a 33.6% improper payment rate, the highest CMS tracks across all specialties. An OIG chiropractic billing audit estimated that $358.8 million, about 82% of the $438.1 million Medicare paid for chiropractic services in 2013, was unallowable. The cause was almost always documentation, not the care itself.
- Subluxation diagnosis with the level. The note names the subluxation and the exact vertebral level, like C4-C6 or L3-L5, and the ICD-10 on the claim matches the region in the SOAP note. “Cervical subluxation” with no level reads as incomplete, and the auditor flags it.
- PART criteria or x-ray evidence. Document at least two of the four PART elements, with one being A or R, or reference the x-ray date and findings that show the subluxation. Pain alone won’t satisfy Medicare’s subluxation proof.
- Spinal regions named, not counted. The SOAP note names each region treated, cervical, thoracic, lumbar, instead of logging “3 regions adjusted.” Unnamed regions on the claim draw CO-11 on audit.
- Active-treatment progress. Every follow-up note shows measurable change since the last visit: a pain score, a range-of-motion reading, or a functional gain. Identical notes across visits read as maintenance care, and Medicare strips the AT modifier on audit.
- Treatment plan with frequency and goals. The initial visit carries a plan with frequency, expected duration, and objective goals, and follow-ups track progress against them. No plan means no medical-necessity basis for the visits that follow.
- Provider signature and date. The billing provider’s signature and the date of service appear on every progress note. For EHR auto-complete, confirm the signature is provider-specific. An unsigned note draws a CO-16 denial on audit.
Practices billing 98941 at volume need the documentation review before submission, not after the denial. One O Seven’s chiropractic RCM services run this six-point check against every CMT claim before it leaves the system.
Denial Codes and FAQ: Resolving Denied CPT 98941 Claims
When Medicare or a commercial payer denies a 98941 claim, the 835 ERA returns a Claim Adjustment Reason Code. Each code points to a specific failure and a specific first move. Reading the CARC before you pull the chart note saves time on the correction and the appeal.
| CARC | Meaning | Common 98941 Cause | First Action |
|---|---|---|---|
| CO-4 | Missing or invalid modifier | Modifier AT missing on a Medicare CMT claim | Confirm AT is on every 98941 Medicare claim; add it and resubmit inside the timely-filing window |
| CO-11 | Diagnosis-procedure mismatch | A low back pain code (M54.50) sits primary instead of the subluxation (M99.03), or the ICD-10 region doesn’t match the CPT region | Move M99.0x to primary; confirm the subluxation code matches the treated region |
| CO-50 | Not medically necessary | AT was present, but review found no documented improvement; maintenance care billed as active treatment | Appeal with objective evidence of progress (ROM readings, pain scores, functional outcomes) at the denied date |
| CO-97 | Service included in another service’s payment | 97140, 97112, or 97124 billed in the same region as 98941 without the right modifier, or 59/XS used without documentation of a separate site | Apply the NCCI same-region rule; for a separate region, name each service’s region and append XS (preferred) or 59 |
A CO-50 after audit is the toughest denial to reverse without objective outcome data. One O Seven’s CO-50 medical necessity denial guide lays out the documentation standard for chiropractic active-treatment appeals.
Each of these denials needs its own appeal package and its own payer-specific documentation. One O Seven’s chiropractic denial recovery team maps every 98941 denial to the right resolution path and files inside 48 hours of receipt.
What does procedure code 98941 mean?
The 98941 CPT code description covers chiropractic manipulative treatment (CMT) of the spine across three to four spinal regions. A chiropractor reports it after adjusting three or four of the five recognized regions: cervical, thoracic, lumbar, sacral, and pelvic. The region count, not the number of adjustments, decides between 98940, 98941, and 98942.
Is CPT code 98941 covered by Medicare?
Yes, for active, corrective manual spinal manipulation that corrects a documented subluxation. The claim needs the AT modifier, and the primary diagnosis has to be an M99.0x subluxation code matching the treated region. Medicare doesn’t cover maintenance care or extraspinal manipulation (98943).
What is the difference between CPT code 98940 and 98941?
The difference is the number of spinal regions treated in one visit. CPT 98940 covers one to two regions; CPT 98941 covers three to four. Both describe the same service, chiropractic spinal manipulation to correct a subluxation, and both need the AT modifier on Medicare claims.
How much is the average reimbursement for 98941?
The 2026 Medicare national average for 98941 runs approximately $38.41 in a non-facility setting. Commercial payers pay more, usually 120% to 200% of the Medicare rate. Your exact number depends on your contracted fee schedule and your geographic locality.
Does 98941 need a modifier?
For Medicare claims, yes. Modifier AT (Active Treatment) goes on every 98941 claim for active, corrective care, and without it Medicare denies the claim as maintenance. For commercial claims, and for non-covered services where the patient signed an Advance Beneficiary Notice, Modifier GA flags the patient’s financial liability.
Can you bill 98941 and 98943 together?
Yes for commercial payers, with Modifier 59 on 98943 and a diagnosis pointed at the specific extraspinal site, separate from the spinal subluxation code. Medicare doesn’t cover 98943 under any circumstances and won’t pay it regardless of the modifier or documentation.
Is CPT code 98941 FSA eligible?
CPT 98941 chiropractic manipulative treatment is usually an eligible expense under an FSA or HSA when the care treats a diagnosed condition. Eligibility comes down to the plan administrator, and some plans ask for a letter of medical necessity from the treating provider.
Practices that bill 98941 every week need a pre-submission process, not a post-denial scramble. One O Seven builds that into your billing workflow, starting with a free CMT billing audit of your current 98941 and 98942 claims against the official 98941 CPT code description.
