ICD code definitions

CPT® Code 97165: Occupational Therapy Evaluation, Low Complexity

June 24, 2026
3 min read
CPT® Code 97165

CPT® Code 97165 is used to report a low-complexity occupational therapy (OT) evaluation. This service involves assessing a patient's occupational performance, functional limitations, and therapy needs to develop an appropriate plan of care.

A low-complexity OT evaluation is typically performed when the patient presents with a brief history, a limited number of performance deficits, and minimal clinical decision-making requirements.

Key Facts About CPT® 97165

  • Service type: Occupational therapy evaluation
  • Complexity level: Low complexity
  • Typical face-to-face time: Approximately 30 minutes
  • Provider type: Licensed occupational therapist or qualified healthcare professional
  • Purpose: Assess functional abilities and develop a therapy plan of care

Common clinical indications:

  • Musculoskeletal injuries or conditions
  • Post-surgical rehabilitation
  • Mild neurological impairments
  • Functional limitations affecting activities of daily living (ADLs)
  • Occupational performance challenges requiring therapeutic intervention

When to Use CPT® 97165

CPT 97165 is appropriate when:

  • The patient requires an initial occupational therapy evaluation
  • The history is brief and uncomplicated
  • The assessment identifies 1–3 performance deficits related to physical, cognitive, or psychosocial skills
  • Clinical decision-making is of low complexity
  • The therapist develops a plan of care based on the evaluation findings

Examples:

  • Evaluating a patient recovering from a minor upper extremity injury
  • Assessing functional limitations following a routine orthopedic procedure
  • Determining therapy needs for mild difficulties with daily activities
  • Conducting an initial OT assessment for a patient with uncomplicated functional impairments

Documentation Requirements

To support CPT 97165 billing, documentation should include:

  • Patient identifiers and date of service
  • Occupational profile and medical history
  • Assessment of occupational performance deficits
  • Objective findings and standardized testing results, if applicable
  • Clinical analysis and low-complexity decision-making rationale
  • Plan of care and treatment recommendations
  • Total evaluation time
  • Therapist signature and credentials

Documentation should clearly support the low-complexity classification.

Reimbursement and Coding Considerations

  • CPT 97165 is used for low-complexity OT evaluations
  • Different complexity levels are reported using 97166 (moderate complexity) and 97167 (high complexity)
  • Documentation must support the complexity level selected
  • Typically billed once per episode of care unless a re-evaluation is medically necessary
  • Diagnosis coding should support the need for occupational therapy services

Always verify payer-specific therapy documentation and billing requirements.

How OptiMantra Supports Occupational Therapy Documentation

OptiMantra’s integrated EMR and practice management system streamlines documentation and billing for CPT 97165:

With OptiMantra, providers can:

  • Document occupational therapy evaluations using customizable charting templates
  • Create and manage therapy plans of care electronically
  • Track patient progress and functional outcomes over time
  • Link evaluations to treatment goals and follow-up visits
  • Maintain organized therapy documentation that supports billing compliance and audit preparedness
  • Streamline scheduling, charting, and patient communication workflows

By centralizing therapy documentation and patient management, OptiMantra helps practices improve efficiency, ensure compliance, and optimize reimbursement.

Try OptiMantra for free here!

Disclaimer: CPT® codes are maintained by the American Medical Association. This guide is for informational purposes only and does not replace official coding guidelines or payer policies.

Jessica Castro
Jessica Castro

Jessica is a Massachusetts-based LPN with 13+ years of experience in patient care, healthcare technology, and education. As the Implementation and Customer Success Manager at OptiMantra, she helps providers optimize EMR solutions for better workflows and patient outcomes. With a Bachelor's in Community Health and a Master's in Healthcare Innovation in progress, she is passionate about leveraging technology to improve care delivery. Through her writing, she shares insights on healthcare best practices, EHR optimization, and patient advocacy to support providers in delivering exceptional care.