If your chiropractor or physical therapist has recommended shockwave therapy after a car accident or other injury, you may have questions about whether your insurance will cover it, whether it will help or hurt your settlement, and what exactly your provider should be doing to protect your claim. These are the right questions to be asking.
At Reardon Injury Law, we are in a position to answer them in a way most personal injury firms cannot. Our founding attorney, John Reardon, practiced as a chiropractor for 20 years before becoming a lawyer. He has treated injured patients, supervised treatment plans, and written clinical notes. He now reviews those same types of records from the other side of the table, evaluating how documentation affects settlement value and how insurance adjusters and defense experts use sloppy billing to attack an entire case. This post translates that dual perspective into plain English for injured patients.
What Shockwave Therapy Actually Is, and Why the Distinction Matters
Not all shockwave therapy is the same, and the difference matters more than most patients realize.
There are two main categories used in clinical practice. The first is Radial Pressure Wave therapy, commonly called RPW, which is widely used in chiropractic and physical therapy offices. It delivers mechanical pressure waves to soft tissue and is often used for myofascial pain, trigger points, and chronic muscle tension. The second is Extracorporeal Shockwave Therapy, or ESWT, which operates at higher energy levels and has a stronger evidence base for specific conditions including plantar fasciitis, calcific shoulder tendinitis, and chronic tendinopathies. ESWT has more formal recognition in medical literature and, in some contexts, more established billing pathways.
Insurance adjusters and defense attorneys frequently lump both categories together and label them experimental or wellness-based. Whether that characterization sticks depends almost entirely on how your provider documents the treatment and how your attorney presents it. A well-documented ESWT course for a post-traumatic supraspinatus tendinopathy is a very different claim than a vague billing entry for “shockwave” applied to generalized soreness after every visit.
Why Documentation Quality Directly Affects Your Settlement
John spent two decades writing clinical notes and supervising treatment plans. He now spends his legal career reading those same types of notes and watching how adjusters respond to them. The pattern is consistent: shockwave therapy that is properly documented strengthens a case, and shockwave therapy that is poorly documented gives the defense a weapon to use against the entire treatment plan.
Here is what good documentation looks like from a patient’s perspective. Your provider’s notes should identify the specific injured structure being treated, not just a general body region. A note that says “left upper trapezius myofascial adhesion” or “right supraspinatus tendinopathy secondary to traumatic mechanism” is far more defensible than “shoulder pain.” The notes should also explain why shockwave was medically necessary at that point in your care, typically because conventional treatment had plateaued and the tissue was not responding to standard modalities.
Beyond the diagnosis, your provider should be recording objective findings at each visit. That means range of motion measurements, palpatory findings like fibrosis or trigger points, orthopedic test results, and functional deficits. These are the clinical markers that demonstrate your injury is real, measurable, and connected to the accident. When an adjuster or defense expert reviews your records, they are looking for exactly this kind of objective data. If it is not there, they will argue the treatment was elective or unnecessary.
Finally, the notes should document the treatment parameters: the region treated, the device used, the number of pulses delivered, the pressure or intensity setting, and how you tolerated the session. This level of detail signals that your provider is running a legitimate clinical protocol, not padding a bill.
How MedPay Coverage Handles Shockwave Therapy in California
MedPay, the medical payments coverage available under California auto insurance policies, is supposed to cover reasonable and necessary medical expenses related to your accident injuries. In practice, MedPay reimbursement for shockwave therapy is inconsistent and heavily carrier-dependent.
Many adjusters default to treating shockwave as experimental or investigational, particularly when they see it billed without strong supporting documentation. Whether your MedPay carrier pays, delays, or denies a shockwave claim often comes down to several factors: the diagnosis listed, the billing code used, the frequency of treatment, the cost per session, and the overall quality of your provider’s notes.
Treatment that is well-documented, priced reasonably, applied selectively rather than at every visit, and tied to a specific traumatic pathology has a much better chance of MedPay reimbursement than treatment that appears on every billing line, carries a high per-session charge, and is supported only by sparse SOAP notes. The latter pattern also gives the bodily injury adjuster on the liability side ammunition to argue that your entire treatment plan was inflated, which can reduce your settlement offer significantly.
The Billing Code Problem and What It Means for Your Claim
There is no universally clean CPT code for most office-based shockwave applications in a chiropractic or outpatient rehab setting. This creates a real risk area that patients should understand even if they are not responsible for solving it.
Some providers use Category III codes like 0101T or 0102T, which were historically associated with focused ESWT for plantar fasciitis and have limited acceptance among commercial carriers. Others use 97039, which is the unlisted modality code and is the most common practical approach for separately billed shockwave. Some providers incorporate the cost into the overall rehabilitation structure without billing it as a standalone line item.
The serious risk is upcoding, meaning billing shockwave as a different service that was not actually performed, such as ultrasound, electrical stimulation, or manual therapy. Defense firms look for this aggressively. If a provider bills shockwave under a code for a different modality, it creates a billing discrepancy that can be used to question the credibility of the entire treatment record. That credibility problem does not stay contained to one line item. It spreads to the whole file.
As a patient, you are not expected to audit your provider’s billing. But you should know that your attorney should be reviewing the billing records before submitting a demand, and any discrepancies should be addressed before they become a defense exhibit.
What Your Provider Should Be Doing, and What You Can Do About It
The clinical decisions belong to your provider. Your job is not to second-guess whether shockwave therapy is the right treatment for your injury. What you can do is make sure your attorney and your provider are communicating, and that both understand how documentation quality affects your case outcome.
John’s guidance to chiropractors who treat personal injury patients includes a specific recommendation that is worth knowing as a patient. Providers should have patients sign a separate document acknowledging the cost of shockwave therapy per session and confirming that the patient understands this cost will be addressed through the settlement. This protects you as well as the provider. Without that acknowledgment, a defense attorney can later argue that you were not on notice about the fees being tied to your settlement, which can complicate the lien resolution process and create disputes at the end of your case.
If your provider has not mentioned this kind of acknowledgment, it is worth asking. It is a straightforward document, and having it in your file eliminates a potential argument down the road.
How Properly Documented Shockwave Therapy Can Strengthen Your Case
When shockwave therapy is used appropriately and documented correctly, it does more than justify a line item on a billing statement. It can affirmatively support the medical narrative of your case in ways that matter at settlement.
Shockwave therapy is typically indicated when soft tissue has not responded to conventional care, when there is evidence of fibrosis, chronic tendon pathology, or myofascial adhesion, and when the clinical picture suggests the injury has moved from acute to subacute or chronic. That clinical picture, when documented clearly, supports several things that are important to your settlement: the severity of the original injury, the fact that recovery required prolonged and specialized treatment, and the reasonableness of your total medical expenses.
In cases where an adjuster is trying to argue that your injuries were minor and should have resolved quickly, a well-documented shockwave treatment course can counter that narrative with objective clinical evidence. John has used exactly this kind of medical record analysis to support higher settlement demands in cases where the initial offer did not reflect the true complexity of the injury.
The inverse is also true. Shockwave applied indiscriminately, billed at inflated rates, and supported only by boilerplate notes gives the defense a straightforward argument that your treatment was excessive. That argument does not stay confined to the shockwave charges. It gets used to cast doubt on the entire treatment plan, which affects every line of your medical bills and, ultimately, your pain and suffering valuation.
What to Do If You Have Questions About Your Treatment and Your Case
If you are currently receiving shockwave therapy as part of your recovery from a car accident or other injury in California, and you are not sure whether your provider’s documentation is protecting your claim, that is a conversation worth having with your attorney now rather than at the end of the case.
We review treatment records as part of every case evaluation we conduct. John’s clinical background means we are not reading those records as legal documents alone. We are reading them the way a defense expert would, looking for gaps, inconsistencies, and documentation that either supports or undermines your claim. When we identify a problem early, there is usually time to address it. When it surfaces at the settlement table, the leverage has already shifted.
If you have questions about your injury case, your treatment documentation, or how shockwave therapy might affect your settlement or MedPay reimbursement, contact us for a free consultation. There is no obligation, and you pay nothing unless we recover for you.