Pulmonary Rehab Billing

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Pulmonary Rehab Billing: A 2025 CPT and Documentation Guide

Pulmonary rehabilitation (PR) has become a cornerstone of care for patients with chronic lung diseases such as COPD, asthma, pulmonary fibrosis, and even long COVID. While the clinical benefits of PR are well-documented, including improvements in exercise tolerance, symptom reduction, and enhanced quality of life, the financial aspect is often overlooked.
For healthcare providers, pulmonary rehab billing can be complicated. Between evolving CPT codes, strict documentation rules, and Medicare/insurance policies, even small mistakes can lead to delayed or denied payments. That’s why having a clear billing process isn’t just helpful, it’s essential for practice sustainability.
This guide breaks down the billing workflow, CPT codes, CMS rules, and documentation requirements for pulmonary rehab in 2025. Whether you run a rehab program, manage a practice, or handle medical billing, this blog will help you understand the essentials and avoid costly mistakes.

Why Pulmonary Rehab Billing Matters in 2025

Revenue cycle management (RCM) in pulmonary rehab goes beyond submitting claims; it safeguards your practice’s financial health and ensures compliance with payer rules. With denial rates for pulmonary services averaging 15–20% higher than other specialties, billing accuracy can make or break your cash flow.

Here’s why it matters more than ever in 2025:

 

  • Growing Patient Demand: With rising COPD prevalence and post-COVID respiratory complications, PR programs are in higher demand. More patients mean more claims and more opportunities for errors.

 

  • Strict Documentation Rules: Medicare requires a physician-prescribed plan of care, reviewed every 30 days, for PR claims. Missing even a single element, such as time logs or supervising physician notes, can trigger denials.

 

  • CMS Incentives and Value Pathways: The Pulmonology Value Pathway (2025) under MIPS ties accurate coding and quality documentation to incentive payments. That means your billing impacts both reimbursement and bonuses.

 

  • Compliance Risks: HIPAA and payer regulations require complete and accurate claim submission. Errors not only delay payments but can also put your practice at risk of audits and penalties.

In short, pulmonary rehab billing is not just about getting paid; it’s about keeping your practice compliant, sustainable, and future-ready.

At MaxRemind, we help practices simplify complex billing workflows so you can focus on patient care. Learn more about our medical billing services.

Step-by-Step Process of Pulmonary Rehab Billing

Just like other areas of pulmonology, pulmonary rehab billing follows a structured revenue cycle workflow. Each stage requires careful attention to detail to avoid denials and ensure steady cash flow. Let’s walk through the process step by step.

Step 1. Pre-Authorization and Insurance Verification

The billing process begins even before the first rehab session. For pulmonary rehab, many payers, including Medicare, require prior authorization. Practices must confirm eligibility, session limits, and medical necessity requirements before scheduling.

Key actions in this step:

  • Verify the patient’s insurance plan covers pulmonary rehab.
  • Check if a prior authorization is needed (especially for commercial insurers).
  • Confirm the number of sessions allowed (Medicare covers up to 36 sessions, extendable to 72 in special cases).
  • Record all authorization details in the EHR for future reference.
This step prevents denials that stem from overlooked pre-approval requirements.

Step 2. Patient Intake and Clinical Documentation

Accurate documentation is the foundation of clean claims. Every PR program must start with a physician referral and a documented plan of care that includes exercise goals, education, and therapy frequency.
During each session, providers must record:
  • Patient attendance
  • Time spent in supervised exercise
  • Education or counseling provided
  • Supervising the physician’s presence
Small lapses, like missing time logs or failure to update the plan every 30 days, are among the most common causes of denials in pulmonary rehab billing.

Step 3. Coding and Charge Entry

After each session, coders assign the correct CPT and ICD-10 codes. Pulmonary rehab uses unique HCPCS/CPT codes that differ from general physical therapy or cardiology rehab codes.
Below is a quick reference table for pulmonary rehab billing codes in 2025:
Procedure/Service CPT/HCPCS Code Example ICD-10 Codes (Medical Necessity) Notes
Pulmonary Rehab, single session
G0237
J44.9 (COPD), U09.9 (Post-COVID), J84.9 (Interstitial lung disease)
Document time and the supervising physician
Pulmonary Rehab, group (per session)
G0238
J44.1 (COPD w/ exacerbation), J98.4 (Other pulmonary disorders)
Must document group education and exercise
Pulmonary Rehab, initial physician visit
G0424
J44.9, J47.9 (Bronchiectasis), G47.33 (OSA)
Required to initiate PR program under Medicare
Extended Pulmonary Rehab sessions (beyond 36)
G0239
U09.9, J84.112 (Pulmonary fibrosis), J42 (Chronic bronchitis)
Must provide justification and updated plan of care
Key points:
  • Always link the CPT code with the correct ICD-10 diagnosis to prove medical necessity.
  • Use modifiers when required (e.g., modifier 25 for significant E/M service on the same day).
  • Double-check against payer LCDs and CMS guidelines for compliance.

Step 4. Claim Submission

Once codes are finalized, claims should be submitted electronically through a clearinghouse or payer portal. For PR, additional documentation is often required:
  • Physician’s plan of care
  • Session notes (including time and supervision)
  • Progress updates every 30 days
Tailoring claim submissions to each payer’s policies helps prevent automatic rejections. For example, Medicare requires documentation that the program is physician-supervised and facility-based, not home-based.

Step 5. Payment Posting and Denial Management

Even with careful coding, denials happen. Common denial reasons in pulmonary rehab billing include:
  • Missing physician signature on the plan of care
  • Exceeding the allowed number of sessions without justification
  • Lack of documentation for group sessions
Practices should have a workflow for quickly correcting and appealing denials. Each denial is an opportunity to tighten your process and reduce future revenue leakage.

Step 6. Reporting and Ongoing Monitoring

Finally, regular reporting ensures your PR billing process stays efficient. Practices should track:
  • Clean claim rate (first-pass acceptance by payers)
  • Denial rate (especially for PR-specific codes)
  • Average days in A/R
Reports also help identify recurring issues, such as staff members missing modifiers or failing to update patient care plans. Continuous monitoring keeps your revenue cycle healthy and compliant with CMS requirements.
Need help streamlining your pulmonary rehab billing workflow? MaxRemind’s medical billing services can reduce denials and improve collections.

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Common Challenges in Pulmonary Rehab Billing (and How to Solve Them)

Billing for pulmonary rehabilitation comes with unique hurdles that can frustrate even the most experienced practitioners. Unlike general medical billing, PR has very specific coding, supervision, and documentation rules that must be met to secure reimbursement. Let’s examine the most common challenges and explore effective ways to address them.

1. Complex Coding Rules

Pulmonary rehab uses unique HCPCS codes (G0237, G0238, G0424, G0239). Submitting the incorrect code or pairing it with the wrong ICD-10 leads to instant denial.

Solution: Keep a coding cheat sheet updated yearly and train staff on payer-specific rules.

2. High Claim Denial Rates

Denials often happen due to missing supervision notes or session time logs. Small gaps in documentation lead to lost revenue.

Solution: Use a session checklist and automate reminders in your EHR to meet all requirements.

3. Prior Authorization Delays

Many commercial insurers require pre-approval, and delays can slow care and payments.

Solution: Assign staff to handle authorizations quickly and log approval numbers in the billing system.

4. Medicare Session Limits

Medicare covers 36 rehab sessions, with possible extension to 72 if medically necessary. Missing counts risks billing for non-covered services.

Solution: Track sessions in your EHR and update the physician’s plan of care before requesting extensions.

5. Documentation Burden

PR requires detailed notes, supervision, goals, progress, and education. Skipping one detail can cause denials.

Solution: Standardize templates and use EHR checkboxes or drop-downs for consistency.

6. Equipment and Compliance Issues

Rehab equipment billing often overlaps with DME coverage, creating confusion.

Solution: Separate PR services from DME billing and ensure proper documentation of medical necessity.

7. Changing CMS Rules

Frequent CMS and AMA updates affect codes, covered conditions, and modifiers. Falling behind risks non-compliance.

Solution: Subscribe to CMS updates or partner with a billing company to stay compliant.

Pulmonary Rehab CPT & ICD-10 Codes Cheat Sheet (2025)

Billing pulmonary rehab requires the correct combination of CPT/HCPCS and ICD-10 codes. Using the wrong code or missing the right one can cause denials and revenue loss. Here’s a simplified cheat sheet for 2025.

Pulmonary Rehab CPT/HCPCS Codes

Code Description Notes
G0424
Pulmonary rehab, per session, including exercise, education, psychosocial assessment, with physician supervision
Most commonly used for Medicare-covered pulmonary rehab sessions
G0237
Therapeutic procedures to increase strength/endurance, 1-on-1, each 15 min
Used when not meeting full PR program requirements
G0238
Therapeutic procedures for endurance, 2+ individuals, each 15 min
Group setting; may apply for some PR programs
G0239
Therapeutic procedures, group, to improve pulmonary function, each 15 min
Often used as an alternative to G0424 when group rehab is documented
94625
Pulmonary rehab, initial session (non-Medicare commercial payers)
Some private payers prefer CPT instead of HCPCS
94626
Pulmonary rehab, subsequent sessions (non-Medicare commercial payers)
Often paired with 94625 for ongoing treatment

Common ICD-10 Codes for Pulmonary Rehab

ICD-10 Code Description
J44.9
Chronic obstructive pulmonary disease, unspecified
J44.1
COPD with (acute) exacerbation
J84.10
Pulmonary fibrosis, unspecified
J84.112
Idiopathic pulmonary fibrosis
J84.89
Other specified interstitial pulmonary disease
U09.9
Post COVID-19 condition, unspecified
J45.909
Unspecified asthma, uncomplicated
I27.20
Pulmonary hypertension, unspecified

Quick Tips for Code Usage

  • Always pair CPT/HCPCS with the correct ICD-10 to show medical necessity.
  • Medicare typically requires G0424, while commercial payers may accept 94625/94626.
  • Document time, supervision, and session count to support coding choices.
  • For post-COVID rehab, U09.9 is now widely accepted.

Keep this cheat sheet handy for staff training and claim reviews. At MaxRemind, we create custom payer-specific code lists for practices to minimize denials. Request your custom cheat sheet today.

Key CMS Updates for Pulmonary Rehab Billing in 2025

Each year, CMS updates coverage rules, payment policies, and compliance requirements that directly impact pulmonary rehab billing. Staying current ensures your claims don’t get rejected and your practice remains compliant. Here are the most important updates for 2025:

1. Expanded Coverage for Pulmonary Rehab

  • Medicare has expanded eligibility to include patients with post-COVID respiratory conditions (ICD-10: U09.9).
  • Patients with pulmonary hypertension (I27.20) are now more frequently covered when medical necessity is documented.

Action Step: Verify eligibility upfront and update your ICD-10 usage to include newly covered diagnoses.

2. Session Limits and Physician Supervision

  • CMS continues to cover up to 36 sessions (twice per week for 18 weeks), with the option for an additional 36 sessions if deemed medically necessary.
  • Direct physician supervision is still required, but CMS clarified that virtual presence via real-time video qualifies under certain conditions.

Action Step: Always track session counts and ensure supervising physician documentation is clear, whether in-person or telehealth.

3. Telehealth and Remote Monitoring Flexibility

  • While G0424 remains the primary billing code, CMS has extended telehealth coverage for education and counseling components of pulmonary rehab in 2025.
  • Remote patient monitoring (RPM) codes (e.g., 99457, 99458) can now be billed alongside PR sessions, if clinically appropriate.

Action Step: Integrate telehealth documentation templates in your EHR to capture both in-person and remote elements.

4. MIPS Pulmonology Value Pathway Alignment

  • CMS is pushing providers toward value-based care with the Pulmonology MIPS Value Pathway.
  • Practices that accurately report quality measures (e.g., improved exercise tolerance, reduced ER visits) may qualify for bonus payments.

Action Step: Train staff to document functional improvements and link them to MIPS reporting.

5. Payment Rate Adjustments

  • CMS has made modest increases in reimbursement for G0424 sessions, reflecting inflation and higher demand.
  • Bundled payments for pulmonary rehab are being tested in certain regions, which may affect how claims are processed.

Action Step: Check your region’s CMS updates for bundled payment models and adjust billing accordingly.

Staying ahead of CMS policy changes can save your practice from denials and compliance risks. At MaxRemind, our experts track CMS updates in real-time so your billing always stays current. Talk to us about CMS compliance support.

Pro Tips to Improve Pulmonary Rehab RCM

Optimizing revenue cycle management (RCM) in pulmonary rehab means more than just submitting clean claims. It requires a proactive strategy that reduces denials, speeds up reimbursements, and ensures compliance with CMS and private payers. Here are some actionable tips:

1. Standardize Documentation

  • Use structured EHR templates for pulmonary rehab sessions.
  • Include mandatory fields: session time, physician supervision, exercise details, and patient progress.
  • Standardization reduces human error and ensures claims are audit-ready.

2. Verify Eligibility Before Starting Rehab

  • Always check Medicare/insurance coverage, session limits, and prior authorization requirements before enrolling patients.
  • This prevents wasted time and denials after services are already provided.

3. Use a Pulmonary Rehab Code Cheat Sheet

  • Keep a quick reference list of CPT/HCPCS and ICD-10 codes handy for staff.
  • Reduces the risk of miscoding between G0424, G0237–G0239, and 94625/94626.

4. Track Denials and Appeals Trends

  • Maintain a denial log that categorizes errors (missing documentation, incorrect codes, exceeded session limits).
  • Review denial trends monthly to identify recurring problems and fix them.

5. Leverage Technology for Claims Management

  • Use claim scrubbing software to catch coding and compliance errors before submission.
  • Implement RCM dashboards to track payments, denials, and outstanding claims in real time.

6. Train Staff Regularly

  • Provide ongoing training in pulmonary rehab-specific billing.
  • Ensure staff understand CMS updates, ICD-10 changes, and payer-specific requirements.

7. Consider Outsourcing to Experts

  • Pulmonary rehab billing is a niche and complex; general billing teams often miss details.
  • Outsourcing to an RCM company specializing in pulmonary billing reduces denials and speeds up payments.

MaxRemind provides end-to-end pulmonary rehab billing services, including coding, compliance, denial management, and reporting. Get started with a free consultation.

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FAQs
How many pulmonary rehab sessions does Medicare cover?

Medicare typically covers 36 sessions (twice per week for 18 weeks). If medically necessary, patients may qualify for an additional 36 sessions, but proper documentation is required.

What CPT/HCPCS code should I use for pulmonary rehab?

For Medicare patients, the primary code is G0424. For some commercial insurers, you may need to use 94625 (initial session) and 94626 (subsequent sessions) instead. Always check payer requirements.

Is pulmonary rehab covered for post-COVID conditions?

Yes. As of 2025, Medicare and most commercial payers cover pulmonary rehab for patients with U09.9 (post-COVID-19 condition, unspecified) when medical necessity is documented.

Can pulmonary rehab be billed via telehealth?

Yes, but only certain components (education, counseling, and some monitoring). CMS allows virtual supervision of pulmonary rehab sessions under specific conditions. Always verify payer telehealth policies.

What is the most common reason for pulmonary rehab claim denials?

The top reasons are incomplete documentation (missing session time logs, physician signatures, or supervision notes) and misuse of CPT/ICD-10 codes.