Riverbend Physical Therapy, LLC
November 12, 2026
Medicare Part B RedeterminationsPO Box 99001Fargo, ND 58108-9001RE: Request for Redetermination
Dear Appeals Reviewer:
Riverbend Physical Therapy, LLC requests a redetermination of the initial determination dated October 9, 2026 denying claim 2226282145830 for services (97110-GP × 8, 97116-GP × 4, 97140-GP × 4) furnished on Sep 8, 2026 through Sep 17, 2026. We ask that the denial be reversed and the claim paid in the amount of $768.00.
The denial
The denial states: “These are non-covered services because this is not deemed a 'medical necessity' by the payer.” (CARC CO-50; RARC N115). Remark code N115 indicates that this decision was based on a Local Coverage Determination (LCD). For therapy services in this jurisdiction, Noridian publishes Article A53304, “Billing and Coding: Medical Necessity of Therapy Services” (effective October 2, 2025).
Why the services should be covered
The record meets each coverage requirement at issue, as follows.
Under the Medicare Benefit Policy Manual, Chapter 15, §220.1.2, the plan of care must be established before treatment is begun and must contain the diagnoses, long term treatment goals, and the type, amount, duration and frequency of therapy services. The plan of care lists diagnoses M17.11 and R26.89 with a start of care of 08/04/2026, and sets long-term goals of LEFS ≥ 50/80, TUG under 12 seconds, gait speed ≥ 0.9 m/s without an assistive device for community distances, right knee flexion AROM ≥ 115°, and a reciprocal stair pattern for 14 steps with one rail. It specifies physical therapy consisting of therapeutic exercise, gait training, manual therapy, neuromuscular re-education and a home program, at 2 visits per week for 8 weeks (16 visits) and up to 60 minutes per visit, and it was electronically signed by Maya Okafor, PT, DPT, on 08/04/2026.
Under the Jimmo v. Sebelius settlement, coverage turns on the need for skilled care rather than potential for improvement, and the progress report documents that continued skilled therapy is needed for balance progression with perturbation, gait training on uneven surfaces and stairs with verbal and tactile cueing, and joint mobilization, which require clinical judgment and cannot yet be done safely through a home program alone.
Chapter 15, §220.1.3 requires a dated signature on the plan of care or other document indicating approval, and initial certification is timely when documented and dated in the 30 days following the first day of treatment, including evaluation. The plan of care carries the statement "I certify the need for these services furnished under this plan of treatment while under my care," signed by Alan Brightwater, MD, and dated 08/10/2026. The initial evaluation was performed on 08/04/2026 and documents that the plan of care was sent to Dr. Brightwater for certification.
Chapter 15, §220.2 requires services of such complexity and sophistication, or a patient condition such, that they can be safely and effectively performed only by a therapist or under a therapist's supervision. The treatment notes for 09/08/2026, 09/10/2026, 09/15/2026 and 09/17/2026 document Grade III posterior and anterior tibiofemoral glides with patellar mobilization to improve knee flexion, and gait and reciprocal stair training with tactile cues for heel strike and knee extension and contact guard on stairs. The therapist documented that the patient required moderate verbal cueing to maintain knee extension in stance on the ramp and contact guard on stairs, and the evaluation found that a TUG of 16.2 seconds and Berg of 44/56 indicate high fall risk.
Chapter 15, §220.2 requires that services be a specific and effective treatment for the patient's condition under accepted standards of practice, with reasonable amount, frequency and duration, and skilled therapy may be necessary to improve, maintain, or slow deterioration of the patient's condition. The evaluation rated rehabilitation potential as good because the patient is motivated, has no cognitive deficits and was independent before this decline, and set target dates of 09/28/2026 for the goals. At the 09/01/2026 progress report, LEFS had improved from 32/80 to 41/80, TUG from 16.2 s to 14.1 s, and gait speed from 0.62 m/s to 0.78 m/s, and the therapist documented measurable progress on every goal.
Chapter 15, §220.3 requires the initial evaluation to document the necessity for a course of therapy through objective findings and subjective patient self-reporting. The 08/04/2026 evaluation measured right knee AROM of 5–98 degrees, right quadriceps strength of 3+/5, LEFS of 32/80, TUG of 16.2 seconds against a fall-risk cutoff of 13.5 s, gait speed of 0.62 m/s against a community ambulation threshold of 0.8 m/s, and a Berg Balance Scale score of 44/56 against a fall-risk cutoff of 45. At evaluation the patient walked with a single-point cane, was limited to about 300 feet by knee pain of 6/10, needed the rail and a step-to pattern on stairs, and reported two falls in the past six months while descending stairs.
Chapter 15, §220.3 requires that progress reports be written by a clinician at least once every 10 treatment days. Maya Okafor, PT, DPT, wrote the Visit 10 progress report dated 09/01/2026, covering the reporting period 08/04/2026 to 09/01/2026. The report re-measured outcomes against the evaluation, including right knee flexion AROM from 98° to 108° against a goal of ≥ 115°, and the billed treatment notes are numbered Visit 11 of 16 through Visit 14 of 16.
Under Chapter 15, §220.3, contractors determine the necessity of services based on the delivery of services as directed in the plan and as documented in the treatment notes and progress report. Treatment notes electronically signed by Maya Okafor, PT, DPT, are in the record for the dates of service 09/08/2026, 09/10/2026, 09/15/2026 and 09/17/2026. Each note records therapeutic exercise for 30 minutes, gait training for 15 minutes and manual therapy for 15 minutes, with total timed code minutes of 60 and total treatment time of 60 minutes.
Clinical summary
The patient, age 72, was referred for right knee pain and difficulty walking with unilateral primary osteoarthritis of the right knee, reported two falls in six months, and had declined from independent community ambulation without an assistive device to walking with a single-point cane. By 09/01/2026 the patient had improved LEFS from 32/80 to 41/80, Berg Balance Scale from 44/56 to 49/56, and pain with walking from 6/10 to 4/10. Fall risk persisted, with TUG still above the 13.5-second cutoff and gait speed below 0.8 m/s, and during the billed visits the patient still required moderate verbal cueing and contact guard on stairs and was not yet safe for community distances without the cane.
For these reasons, we ask that you reverse the denial and pay the claim. If the denial is upheld, please identify the Local Coverage Determination applied (remark code N115), the specific provisions of it or of Article A53304 that these services are said not to meet, and the documentation you relied on. Please contact Sam Rivera at (503) 555-0142 ext. 2 with any questions.
Sincerely,

Maya Okafor, PT, DPT
Clinic Director













