In skilled nursing facilities, CPT 97530 (Therapeutic Activities) is one of the most functionally rich, clinically powerful interventions therapists can provide. Yet despite its value, it is often misunderstood, misapplied, and underutilized.

Many clinicians refer to 97530 as the “–ing code” because it involves engaging patients in doing meaningful, functional activities. However, a common misconception persists: that any activity or education falls under 97530. In reality, education alone does not meet the criteria for 97530, and selecting it simply because teaching occurred is a coding error. 

What 97530 Actually Is

The CPT definition of 97530 is “therapeutic activities, direct (one-on-one) patient contact (use of dynamic activities to improve functional performance), each 15 minutes.”

This includes clinician-directed, functional task-oriented activities such as:

• Lifting
• Carrying
• Handling
• Reaching
• Transferring
• Transporting

It is not just performing an activity, it is the therapist’s analysis, grading, cueing, environmental setup, and clinical problem-solving during the functional task that make the service skilled.

 

What 97530 Is Not

97530 is Not:

• Verbal instruction without active performance
• Watching a demonstration
• A passive experience
• Simply “any activity the patient completes”

If you are educating, you bill the most appropriate code for the service being taught (e.g., 97535 for self-care training). Education paired with functional performance may fall under 97530, but education by itself does not.

 

Are We Underutilizing 97530?

There is a strong possibility that 97530 is used less than it should be. This is not because clinicians are doing less functional retraining, but because they default to other codes when they’re actually providing therapeutic activities.

For example, if the patient is actively practicing sit-to-stand transfers with graded cueing to improve functional mobility, that activity is almost certainly therapeutic activities, even if the therapist is also instructing them.

 

Accurate Use of 97530 is About Ensuring:

• The code matches the intervention
• Documentation reflects the skilled service performed
• The patient receives functional, meaningful therapy aligned with SNF goals

 

Coding Tips for Everyday Compliance:

• Understand CPT coding definitions
• Code only what is actually performed
• Report only skilled minutes
• Ensure documentation supports each code billed
• Follow payer and regulatory rules
• Remember: each minute billed must reflect skill, intent, and necessity

 

Clinicians are the heart of the compliance team. Coding is not just billing. It’s a clinical integrity practice. Accurate, intentional coding protects patients, clinicians, and the SNF.

 

Written By: Sheena Mattingly, EVP of Quality & Compliance

Did you know?

One of the simplest ways to stay healthy as we get older is just… keep moving! Every movement you make, big or small, helps your body stay strong, flexible, and ready for whatever life brings.

But staying active isn’t always easy. Stiff joints, arthritis, or the natural changes that come with aging can make even simple activities, like going for a walk or climbing stairs, more challenging. That’s where physical therapy can help. Physical therapists are movement experts who work with older adults to make staying active easier, more comfortable, and safer.

How Physical Therapy Supports Healthy Aging:

Better Balance – Even small changes in balance can increase fall risk. Physical therapy helps identify these issues early and teaches strategies to keep you steady and safe.

Builds Strength– Gentle, targeted exercises to build muscle and stamina so you can enjoy everyday activities.

Manages Pain– Therapy can help reduce stiffness and soreness to make daily movement feel easier.

Promotes Independence – Staying active means staying in charge of your daily life and continuing to do the things you love.

 

If you’ve noticed changes in your balance, strength, or mobility, or if movement feels more challenging than it used to, talk with your doctor to see if physical therapy can help. Sometimes the smallest steps lead to the biggest improvements in health and independence.

Lessons from Recent OIG Audit Findings

 

A recent audit by the U.S. Department of Health and Human Services Office of Inspector General (OIG) revealed serious gaps in verifying nursing home staff background checks in Alabama. While the audit focused on one state, the implications are far-reaching and relevant for operators nationwide.

 

Key Findings from the OIG Audit (Alabama Audit A-04-24-08104)

The audit examined nursing home compliance between January 1, 2022, and April 8, 2024, reviewing 439 employees across sampled facilities. It was discovered that 139 employees did not have properly verified background checks or registry queries performed before beginning work.

Based on these findings, the OIG made four strong recommendations to the Alabama Department of Public Health (ADPH), urging:

1. Implementation of a process to verify background checks and registry queries before employee onboarding.
2. Education efforts to inform facilities about the critical importance of timely background verification.
3. Requirement for facilities to establish formal policies and procedures for registry queries prior to employment.
4. Conducting ongoing reviews of facility compliance with these requirements.

As of now, all four recommendations remain open and unimplemented, with further action expected by early 2026.

 

Broader Implications & Why This Matters Across States

Although this audit focused on Alabama, the risks and lessons apply universally:

• Nursing home residents rely on trusted, screened staff. Lapses in background verification can significantly compromise safety.
• Other states may face similar audits, and the trend toward heightened oversight is increasing, especially around employee screening procedures.
• Like Alabama, other states could be prompted to institute mandatory pre-employment verification, backed by audits or sanctions.
• Facilities lacking consistent background screening could face reputational damage, regulatory action, or worse.

 

Are you Compliance Ready?

 

 

The OIG audit serves as a reminder that compliance cannot be reactive and instead must be built into daily operations. Nursing homes that establish robust, proactive screening processes not only reduce regulatory risk but also strengthen trust with residents, families, and communities. By taking action now, providers can position themselves as industry leaders in both resident safety and regulatory readiness.

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