Clarification of Federal Home Health Agency Interpretive Guideline Tag G161

August 1999

Information Bulletin 99-19

Clarification Of Federal Home Health Agency Interpretive Guideline Tag G161


The purpose of this information bulletin is to clarify the language in the Federal Certification Home Health Agency Interpretive guideline Tag at G161 as provided by the Health Care Financing Administration (HCFA) Regional Office. This tag provides guidance to interpreting the regulation at 42 CFR 484.18(a).


The regulation at Tag G161 reads:

"Orders for therapy services include the specific procedures and modalities to be used and the amount, frequency, and duration."

"Modalities" are defined as any physical agent applied to produce therapeutic changes to biologic tissue and include, but are not limited to, thermal, acoustic, light, mechanical, or electric energy.

"Procedures" are defined as a manner of effecting change through the application of clinical skills and/or services that attempt to improve function. This can be achieved through exercise or training and must include active interaction between therapist and beneficiary.

Modalities that are supervised but do not require constant patient contact (by the provider) include hot or cold packs, traction, mechanical or electrical stimulation(unattended), acupuncture with electrical stimulation, vasopneumatic devices, paraffin bath, microwave, whirlpool, diathermy, infrared and ultraviolet.

Modalities requiring constant attendance include electrical stimulation (manual), iontophoresis, contrast baths, ultrasound and Hubbard tank.

Items such as Theraband, free weights and stationary bikes are not considered modalities. They are considered equipment or items used in support of a procedure such as therapeutic exercise (CPT code 97110) or neuromuscular reeducation (CPT code 97112). Procedures and modalities are listed in the Current Procedure Terminology (CPT) manual. There are no CPT codes for such items as Theraband, free weights and stationary bikes. Therefore, citations should not be issued at Tag G161 nor any other Tag (i.e. G162 or G165) for a lack of specific orders regarding Theraband, free weights and stationary bikes.

Currently, Tag G161 is the only Tag where deficiencies regarding lack of specificity for procedures and modalities should be cited.

If you have any questions regarding this information bulletin, please contact in writing

Minnesota Department of Health
Health Regulation Division
Licensing and Certification Program
85 East Seventh Place, Suite 300
PO Box 64900
St. Paul, Minnesota 55164-0900

Updated Thursday, February 06, 2020 at 02:05PM