How to Count ‘Performance Deficits’ in the New OT Evaluation Codes

Please note that this article contains information that is only relevant to American clinics.


A couple weeks ago we discussed elements and how they fit into the new PT evaluation codes. But this week, we’re going to take a closer look at the new OT evaluation codes and their relation to performance deficits.


Let’s begin by defining performance deficits. The CMS considers a performance deficit to be the inability to complete activities due to the lack of skills in one or more of the following categories (relating to physical, cognitive, or psychosocial skills). Now we’ll look at how they fit into the evaluation.


As you know, there are three kinds of OT evaluations; low complexity OT evaluations (CPT 97165), moderate complexity OT evaluations (CPT 97166), and high complexity OT evaluations (CPT 97167). What you may not have known is that the evaluation’s complexity level is determined by the number of performance deficits.


Click here to read the American Occupational Therapy Association’s document on ‘Performance Deficits’.


A low complexity OT evaluation contains 1 to 3 performance deficits, a moderate complexity OT evaluation contains 3 to 5 performance deficits, and a high complexity one has 5 or more.


Examples of ‘Performance Deficits’ in an OT Evaluation


With the help of Gawenda Seminars and Consulting, we’re going to provide you with an example of a situation in which you would be providing an occupational therapy evaluation, and the number of ‘Performance Deficits’ included.
Let’s pretend that a 34-year-old woman named Elizabeth was loading the trunk of her SUV with groceries when a particularly heavy bag got caught on the bumper, causing her to drop her bag. The sudden shock ended up tearing her right shoulder’s rotator cuff, which she had to have surgically repaired. It’s been six weeks since then and she’s still experiencing some severe limitations.


Elizabeth claims to have trouble lying down and it’s preventing her from getting a full night’s sleep. The pain really starts to flare up when she attempts to use her right shoulder. This is preventing her from day-to-day activities like washing the dishes and shampooing her hair in the shower. Furthermore, Elizabeth’s job involves a lot of lifting and she’s been unable to go to work since her injury. Now let’s review some of the performance deficits highlighted in our subjective evaluation:


  • Elizabeth has indicated the inability to sleep through the night. This is a performance deficit.
  • Elizabeth hasn’t been able to clean up after cooking herself a meal. This is also a performance deficit.
  • She’s also been off work for the past few weeks. This counts as a performance deficit.
  • Elizabeth mentioned that she hasn’t been able to shampoo her hair. This is a performance deficit, too.


Based on our subjective evaluation, we’ve been able to identify four unique performance deficits. But please bear in mind that this is merely an example. If you wish to learn more about what qualifies as a performance deficit, check out the link below.


Click here to access the Occupational Therapy Practice Framework: Domain and Process to see the full list of performance deficits.  


We hope that you found this article helpful, and we’d like to encourage you to look into the benefits of becoming a Gold Member on Gawenda Seminars and Consulting.