Let’s not mess around with the textbook answer. You’ve got that dull, constant ache in your neck from the whiplash, and your physical therapist told you a few sessions of targeted massage myofascial release, deep tissue—would do you a world of good. So, you want to know: will insurance actually pay for this?
The short, honest answer is a qualified YES, they will often pay for massage therapy after a car accident, but only if you follow their bizarre, frustrating rulebook exactly.
This is not a straightforward bill like a prescription or an MRI. Massage therapy falls into a Gray area the insurance industry calls “conservative care.” It’s right next to chiropractic adjustments and acupuncture. The insurance adjuster is trained to look at it with deep suspicion, because in their mind, “massage” equals “spa day,” and they aren’t paying for your vacation.
If you want this paid for, you can’t just send them a bill. You have to prove, without a single doubt, that the treatment is medically necessary and not just something that feels nice. If you fail to do this, the denial letter will be in the mail before you’ve even finished your first session.
The Line in the Sand: Necessity vs. Comfort
Your entire success hinges on how your treatment is ordered and documented. The insurance company pays for treatment designed to restore function. They do not pay for treatment designed to temporarily relieve stress.
What They Are Looking For (Your Proof)
Every piece of paper, every note taken by the therapist, has to scream CLINICAL.
- The Prescription Must Be Ironclad: You can’t just get a verbal suggestion. You need a formal prescription from a medical doctor (MD or DO), ideally one who specializes in rehabilitation (a Physiatrist). The prescription cannot just say “Massage Therapy.” It must specify the type of therapy (“manual therapy,” “myofascial release”), the duration (“12 sessions”), the frequency (“2 times per week”), and, most importantly, the Goal (“To increase cervical rotation from 45 to 70 degrees”).
- The Right Codes: The billing office must use the correct CPT codes. If they use a code for a generic, hour-long massage, it’s denied. They need to use codes like 97140 (Manual Therapy) or 97124 (Therapeutic Massage), which indicate a targeted, clinical procedure, not a relaxation service.
- Measurable Progress: This is the most critical audit point. The therapist’s notes must document measurable changes. Example of Good Note: “Patient presented with a 4/5 spasm in the left trapezius. Post-session, spasm reduced to 2/5, and range of motion improved by 5 degrees. Continue treatment to break the knot.” If the notes just say, “Patient reported feeling better,” it’s denial material.
The Denial Red Flags
If you step into the insurer’s traps, you lose. They are looking for:
- Treatment Gaps: If you miss a week or two of physical therapy, the insurer argues your pain wasn’t that bad, and the new massage is unnecessary.
- Open-Ended Prescriptions: If the doctor just says “as needed,” the adjuster sees a permanent commitment and will shut it down immediately, claiming the treatment is “palliative” (just temporary relief).
- Spa Setting: If your treatment is taking place in a luxurious spa environment rather than a dedicated medical or chiropractic clinic, the adjuster will claim it is not medically appropriate.
The Strategic Battle: PIP vs. Liability Claims
Where the money comes from depends on your state, and this affects how hard you have to fight.
If You Are in a No-Fault State (PIP)
In states like Michigan or Florida, your own Personal Injury Protection (PIP) pays the bills first. This is usually the easier funding source, but it has one big downside: it runs out.
The insurance company knows your total PIP fund is capped (e.g., $50,000). They will readily approve high-cost, mandated treatments like MRIs and surgeries. But they’ll often drag their feet on low-cost treatments like massage, hoping that the money runs out before they have to approve the softer care. You must get the massage ordered and approved early so it’s budgeted for. Don’t wait three months; that’s when they start looking for reasons to audit your claim.
If You Are in an At-Fault State (Liability)
If the at-fault driver’s insurance is paying your claim, they will fight every massage bill just to keep the final settlement low. Why?
Because every dollar they pay for medically necessary treatment—including massage—is used by your lawyer to calculate the value of your pain and suffering (the multiplier method). If they can cut your $5,000 massage bill, they might save $20,000 on the final settlement.
Your Counter-Strategy: Don’t let them intimidate you. The massage therapy is often what saves you from needing more expensive things like cortisone shots or even surgery down the line. A good lawyer will argue, “We utilized conservative, recognized treatments, like manual therapy, to keep costs down and prevent long-term damage.”
Insider Advice: Don’t Deal with the Adjuster Yourself
Trying to argue the medical necessity of myofascial release with a call center adjuster who failed their high school biology class is a recipe for a migraine. The fastest way to get massage therapy approved is to take the decision out of the adjuster’s hands.
Let the Doctor Be the Authority
When you see the doctor, tell them: “I am experiencing severe muscle rigidity and spasms. My physical therapist suggested manual therapy, but I need your written, clinical order so the insurance company can’t fight it.”
The doctor’s signature on a detailed, goal-oriented prescription is the only thing the insurance company’s utilization review nurse respects. The doctor is stating, as a matter of medical expertise, that this treatment is required. They can’t argue with that without spending thousands of dollars to get a counter-opinion.
Let the Billing Office Do the Fighting
Find a physical therapy or chiropractic clinic that is experienced in personal injury (PI) claims. They are used to dealing with the denials. They know which CPT codes to use, how to write the progress notes, and how to appeal a denial. They will often bill the insurance company directly, taking the paperwork fight off your plate. If your clinic tells you, “We can’t bill insurance,” find a new clinic immediately. They are signalling that they don’t want to do the paperwork required to prove medical necessity.