CPT code 97165: OT evaluation, low complexity2026 Medicare rate & RVUs

Report 97165 for a low-complexity occupational therapy evaluation assessing functional performance and establishing or updating the patient’s therapy plan.

CMS RVU26DEffective Oct 1, 2026109 payment localities185.8K Medicare services in 2024

Medicare pays $100.54 for 97165 nationally in the office. Local office rates run $93.50–$129.28.

Medicare rate · 97165

OT evaluation, low complexity

Office or facility?

Work RVUs
1.54
Total RVUs
3.01
Global days
XXX

National rate · 2026

$100.54

Office setting, before claim adjustments.

See every locality for 97165 →Billed by an NP, PA or therapist? →

Medicare allowed amount for participating (non-QP) physicians, before deductible, coinsurance and claim adjustments. Not a patient’s bill or a hospital charge.

Your location

Medicare pays by the payment locality where the service is performed.

On this page 10 sections
  1. Medicare rate
  2. What 97165 covers
  3. By payment locality
  4. Rate map
  5. How it’s calculated
  6. Payment rules
  7. Similar codes
  8. Related codes
  9. Billing questions
  10. Sources

What 97165 covers

An occupational therapist evaluates how a patient performs daily activities, such as dressing, bathing, cooking, or using the hands for work and self-care. The therapist gathers a focused occupational profile and relevant medical or therapy history, identifies performance problems, and determines whether skilled occupational therapy is appropriate. Evaluations commonly take place in outpatient clinics, rehabilitation settings, or other locations where occupational therapy is provided.

Choose this level when the evaluation involves low-complexity clinical decision making, a limited number of performance deficits, and few needed modifications to the assessment. Document the profile and history reviewed, functional findings, clinical reasoning, and resulting plan of care. The code identifies an evaluation service, not a unit selected by elapsed treatment time. Medicare treats it as a therapy service rather than separate professional and technical claims. When multiple therapy services are furnished on the same day, practice expense is reduced for the second and later therapy units.

This summary was written with AI assistance from CMS physician fee schedule data and checked against the CMS billing rules shown here. Rates on this page come directly from CMS files.

Where 97165 pays more and less

The same RVUs, adjusted for each area’s costs. Open a locality for its calculation, history and nearby areas.

109 payment localities

$93.50 to $129.28

$93.50$111.39$129.28
One dot per payment locality, office / nonfacility. Hover a dot to see the locality; select it to open that rate.

109 of 109 payment localities

97165 office and facility rates by payment locality
Payment localityOfficeFacility
Alabama$94.30Unavailable
Alaska$129.28Unavailable
Arizona$98.98Unavailable
Arkansas$93.50Unavailable
Atlanta, GA$101.54Unavailable
Austin, TX$103.43Unavailable
Bakersfield, CA$106.06Unavailable
Baltimore area, MD$105.00Unavailable
Beaumont, TX$96.12Unavailable
Brazoria, TX$100.44Unavailable

97165 rates by state

Office rate range in each state. Select a state to see its payment localities.

Explore a state

Local rates. Clear comparisons.

Hover or focus a tile to see its rate range. Select it to open the state’s fee schedule.

$93.50

$129.28

Color shows the midpoint of each state’s locality range.

View every state and territory as a table
97165 office rate range by state
State / territoryOffice rate rangeLocalities
AK$129.281
AL$94.301
AR$93.501
AZ$98.981
CA$105.94–$127.5929
CO$104.201
CT$105.391
DC$112.031
DE$100.171
FL$98.56–$103.053
GA$95.33–$101.542
GU$107.081
HI$107.081
IA$96.191
ID$96.461
IL$96.48–$102.474
IN$96.811
KS$95.691
KY$95.101
LA$94.91–$97.702
MA$103.88–$112.072
MD$101.61–$112.033
ME$96.51–$99.972
MI$96.34–$99.062
MN$101.721
MO$93.80–$98.203
MS$93.671
MT$100.541
NC$97.151
ND$100.341
NE$96.571
NH$102.491
NJ$107.11–$111.602
NM$96.561
NV$100.531
NY$98.00–$113.335
OH$96.301
OK$95.241
OR$100.24–$106.692
PA$96.52–$103.532
PR$101.071
RI$103.091
SC$96.781
SD$100.311
TN$95.941
TX$96.12–$103.438
UT$97.581
VA$99.61–$112.032
VI$101.071
VT$99.881
WA$103.71–$114.122
WI$98.261
WV$94.291
WY$100.451

How the 97165 rate is calculated

Each of 97165’s three RVUs is multiplied by a geographic index (GPCI) for the payment locality, added up, and multiplied by the conversion factor. Drag the indexes or enter a ZIP to see what moves the rate.

How the rate is built · 97165

RVUs × geographic indexes × conversion factor

Office or facility?

Work1.54

1.54 RVUs× 1.000 GPCI

Practice expense1.46

1.46 RVUs× 1.000 GPCI

Malpractice0.01

0.01 RVUs× 1.000 GPCI

Adjusted RVUs

3.0100

Conversion factor

$33.4009

Medicare rate

$100.54

Every GPCI starts at 1.000, the national rate. Enter a ZIP or drag a slider.

Payment rules and modifiers for 97165

The CMS indicators that decide how 97165 is paid alongside other services.

CMS payment indicators · 97165

OT evaluation, low complexity

RuleCMS valueWhat it means
Global periodXXXThe global surgery concept doesn’t apply.
Multiple procedures5Therapy reduction: practice expense of the second and later units is reduced.
Bilateral (modifier 50)0The 150% bilateral adjustment doesn’t apply.
Assistant at surgery (80/81/82/AS)0Not paid without supporting documentation.
Co-surgeons (62)0Not permitted.
Team surgery (66)0Not permitted.
Professional/technical7Therapy service: the split doesn’t apply.

What modifiers do to the payment

Modifier CQ · payment effect

With and without the modifier

97165 without CQ · national office

$100.54

OT evaluation, low complexity

97165-CQ · Allowed amount unchanged

$100.54

Medicare cuts its own payment by 15% after the patient’s 20% coinsurance; the allowed amount stays the same. On $100 allowed: $20 coinsurance, then Medicare pays $68 instead of $80.

97165 compared with similar codes

Compare codes · National

5 codes, side by side

Office or facility?

  • 97165

    OT evaluation, low complexity1.54 wRVU

    $100.54

  • 97166

    OT evaluation, moderate complexity1.54 wRVU

    $100.54+$0.00

  • 97167

    OT evaluation, high complexity1.54 wRVU

    $100.54+$0.00

  • 97168

    OT reevaluation, established plan of care0.96 wRVU

    $68.47−$32.07

  • 97161

    PT evaluation, low complexity, typically 20 minutes1.54 wRVU

    $97.86−$2.68

How to choose

97166OT evaluationModerate complexity
Use 97166 when the occupational therapy evaluation supports moderate rather than low clinical decision-making complexity.
97167OT evaluationHigh complexity
Use 97167 for a high-complexity occupational therapy evaluation; 97165 represents the low-complexity level.
97168OT reevaluationEstablished plan of care
Use 97168 for reevaluation of an established occupational therapy plan of care, rather than an initial low-complexity evaluation.
97161PT evaluationLow complexity, typically 20 minutes
97161 is a low-complexity physical therapy evaluation. Choose 97165 when the evaluated service is occupational therapy.

97165 billing questions

How is 97165 different from 97166?

Use 97165 when the evaluation supports low-complexity decision making, limited performance deficits, and few assessment modifications. The moderate-complexity level, 97166, reflects greater evaluation complexity.

Is 97165 selected by the number of minutes spent?

No. Select the level from the evaluation’s complexity and documented findings; the code’s stated time is not a threshold for choosing 97165.

Can an occupational therapist bill treatment on the evaluation date too?

Distinct treatment services may be reported when separately furnished and documented. Medicare’s therapy multiple procedure payment reduction lowers practice expense for the second and later therapy units that day.

Should modifier 26 be appended to 97165?

No. Medicare treats 97165 as a therapy service, not as separate professional and technical components.

What documentation supports the low-complexity level?

Record the occupational profile and history reviewed, functional performance deficits found, clinical decision making, any assessment modifications, and the plan of care.

Where these rates come from

FeeBase calculates base physician payments from CMS work, practice-expense and malpractice RVUs, adjusted by each locality’s geographic indexes and the conversion factor. Services without a published rate are labeled, never given a made-up amount. Amounts are Medicare allowed amounts before claim adjustments: not a patient’s bill or a commercial rate.

CMS RVU26D · effective Oct 1, 2026 through the day before Jan 1, 2027

Show the CMS file lines behind this rate
RVUs for 97165PPRRVU2026_Oct_nonQPP.csv, line 12,881 (RVU26D)

Open CMS sourceHow we calculate rates

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