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Are Strapping (Multilayer Compression System) Codes Usable to Bill Lymphedema Bandaging Services?v2014-11-13

2015 CPT® no longer excludes simultaneous multilayer bandaging and MLD.

On November 11, 2014 The AMA CPT Editorial Board announced in their Errata and Technical Corrections – CPT® 2015 that the exclusionary parenthetical note following CPT® 97140 referencing the multilayer compression system codes CPT® 29581-29584 was being deleted, thereby allowing the billing of the strapping and MLD codes on the same day on the same patient. This paves the way for the use of the strapping codes for bandaging after manual lymph drainage. NCCI Edits for 2015 have been changed to reflect this change. Further CPT code descriptions must be made expanding the use of previous "strapping codes" to other than musculoskeletal and venous conditions, and CMS must now follow up and remove restrictive wording in their coding and billing instructions.

I wrote the following in my July-Sep 2012 column in LYMPHLink. I have been told that it is not correct, and that these new codes can be used for lymphedema wrapping together with 97140, but I have not seen any Medicare documentation that makes that possible, i.e. a new or changed LCD that lists lymphedema diagnostic codes to the CPT 295xx. Until then, these codes are only indicated for "strains, sprains, dislocations, tendonitis and certain fractures not accompanied by ulceration." Later clarifications published in 2012-2014 have confirmed my original interpretation that the strapping codes 2958x are not usable for lymphedema bandaging despite efforts to make that happen.

Strapping Codes
NLN LymphLink Volume 24, No. 3

The 2009 National Correct Coding Initiative Policy Manual for Medicare Services defined the Current Procedural Terminology (CPT®) for three strapping protocols (See Table 1) for wrapping lower extremities in the treatment for musculoskeletal diagnoses, e.g. fractures, dislocations, prains. The Unna Boot was considered medically reasonable and necessary to also treat venous vascular insufficiency and venous ulcers.

It was generally expected that strapping of the ankle, foot and/or toes would be done not more often than once per week, and application of the Unna Boot not more often than once or twice per week. Lymphedema diagnostic codes were not included as supporting medical necessity for any strapping CPTs. [Local Coverage Determinations (LCDs) for STRAPPING: L28986, L29018, L29314, L29320]

In 2010 a fourth strapping code, 29581, was added to provide Medicare coverage for strapping of a leg with multi-layer compression dressings as part of venous ulcer treatment. Here again, presence of a venous ulcer supported medical necessity, and lymphedema did not.

The addition of CPT® codes in 2012 to cover strapping of upper extremities as well as lower extremities was accompanied by exclusionary parenthetical notes precluding provision of these strapping services on the same day as manual therapy CPT® 97140. In a February 2012 AMA CPT® Editorial Panel Meeting the AMA Panel accepted the recommendations of the American Physical Therapy Association and American Academy of Physical Medicine and Rehabilitation, and deleted the 97140 exclusionary notes to the strapping codes to allow separate reporting of these services. [February, 2012 CPT® Editorial Panel Meeting, Summary of Panel Actions, Tab #20]

However, a new strapping LCD must be written if the intention is to use strapping codes in the treatment of lymphedema, with lymphedema diagnostic codes supporting medical necessity of strapping, and strapping materials not limited to multi-layer disposable dressings. Otherwise the decoupling of strapping from manual lymph drainage (MLD)/complex decongestive therapy (CDT) CPT® 97140 will not help the lymphedema patient or therapist in billing Medicare for conventional compression wrapping with short stretch compression bandages, padding, finger/toe wraps, etc as part of CDT. Issues also remain in defining the required qualifications for the medical personnel performing musculoskeletal strapping VS wound care for venous ulcers VS lymphedema compression wrapping.

YearCPT®Protocol DescriptionSupply Item
200929540Strapping; Ankle and/or FootNonmedicated, adhesive gauze dressings, applied by overlapping wraps of gauze
 29550Strapping; Toes
 29580Strapping; Unna BootPaste bandage, multi-layers of impregnated gauze
201029581Application of multi-layer venous wound compression system; below the kneeDressing, Multi-layer system, Venous ulcer (SG093)
201229582Application of multi-layer compression system; thigh and leg, including ankle and foot, when performedMulti-layer compression system bandages (SG096)
 29583Application of multi-layer compression system; upper arm and forearmMulti-layer compression system bandages (SG096)
 29584Application of multi-layer compression system; upper arm, forearm, hand and fingersMulti-layer compression system bandages (SG096)

Table 1. STRAPPING CPT CODES & SUPPLY ITEMS

It is important to note that strapping, CPT 295xx, is not considered by Medicare to be a skilled service, and can be provided by any medical provider, specially trained or not, as long as it is within the scope of practice of the provider. I believe that is why it is only reimbursed with one unit, and is not a timed service.

UPDATES AND CLARIFICATIONS 2012, 2013 and 2014

Medicare A News, April 11 2012
Heading: Billing
Title: High Compression Bandage System Clarification

Multi-layered, sustained, graduated, high compression bandage systems are used primarily to treat lymphedema and venous or stasis leg ulcers. In recent years a number of graduated, high-compression bandage systems products have been developed, including Profore®, Dyna-Flex®, Surepress®, Setopress®, and other similar product systems.

Providers should note that the treatment of lymphedema with the application of high compression bandage systems continues to be non-covered by Medicare. However, a brief period, i.e. three or fewer sessions if no new specific issues are identified, of patient and/or caregiver education for home management of lymphedema with compression wrap applications may be medically necessary and reimbursable. Medical necessity for the education must be clearly indicated in the patient's record and must meet the code descriptor requirements for CPT® 97535, supporting home management training.

Following review of the current literature, the practices of our providers, and the January 2012 implementation of the specific CPT codes describing the application of multi-layered compression bandage systems, NAS will cover and separately reimburse the costs of the following procedures for applications that do meet Medicare coverage requirements:

Note: These codes should not be reported in conjunction with CPT 97140.

This article supersedes all other NAS publications on this subject.
Effective for dates of service on or after January 1, 2012
Posted on: 4/11/2012
CPT codes, descriptors and other data only are copyright 2008 American Medical Association (or such other date of publication of CPT). All Rights Reserved. Applicable FARS/DFARS apply.


A later interpretation may be found in the NCCI Edit Manual 2013, Chapter 2. Section F, Fractures, Dislocations, and Casting/Splinting/Strapping:

New for 2013 is the following: Application of a multi-layer compression system (CPT codes 29581-29584) include manual therapy in the anatomic region of a multi-layer compression system. CPT code 97140 (manual therapy techniques…) should not be reported for any type of manual therapy at the same patient encounter in the anatomic region where a multi-layer compression system is applied.


And in the National Correct Coding Initiative Policy Manual for Medicare Services, Chapter IV Surgery, Musculoskeletal System CPT Codes 20000-29999, Revision Date: 1/1/2014:

15. Application of a multi-layer compression system (CPT codes 29581-29584) includes manual therapy in the anatomic region of the multi-layer compression system. CPT code 97140 (manual therapy techniques...) should not be reported for any type of manual therapy at the same patient encounter in the anatomic region where a multi-layer compression system is applied.