DIET & NUTRITION 
PATIENT EDUCATION 
OBESITY/WEIGHT MANAGEMENT 
EXERCISE/TRAINING 
LEGAL MATTERS 
GUIDELINES/RECOMMENDATIONS ⚖️ Legal / Ethical Complexity
CPT 0936T (photobiomodulation of retina, single session) launched January 1, 2025 to support reimbursement for the FDA-authorized Valeda Light Delivery System. MAC payments vary geographically, and most state regulations bar medical assistants from performing PBM.
Professional Impact
- Code 0936T reports one session per day with modifier 50 for bilateral; codes 0552T, S8948, and 97037 do not apply to retinal PBM.
- MACs make claim-by-claim determinations, and CMS assigned no allowed amount to 0936T in the 2025 Medicare Physician Fee Schedule.
- MAC medical directors confirmed in March 2025 that MAs and ophthalmic technicians should not administer PBM, even under physician supervision.
- “Incident to” billing reimburses at 100% only when the QHP is credentialed, employed, physician-supervised, and treating an established patient.
Action Items
- Verify state scope-of-practice rules for any optometrist, PA, NP, or QHP performing PBM before scheduling cases.
- Document medical necessity per Valeda indications: BCVA 20/32-20/70 with qualifying drusen or noncentral geographic atrophy.
- Issue an ABN, benefits determination, or Notice of Exclusion before treatment given coverage uncertainty.
- Train billing staff to apply modifier 50 for bilateral PBM and modifier 25 only when a separately documented exam is performed.
Related Reading
