D9110 vs D0140: A Common Coding Confusion

October 31, 2017

Updated 12/26/25

At the emergency or routine visit, there could be several coding options available if the patient reports pain or discomfort. As always, the dentist should determine the current CDT code that best describes the overall context of the procedure, and the patient’s record must support the D9110 procedure performed and reported. Always report “what you do” using the CDT code that best describes the procedure performed.

Using D0140 vs D9110

Understanding D0140: Problem-Focused Oral Evaluation

D0140 is the CDT code used to report a limited oral evaluation that is problem-focused. The descriptor states: 

“An evaluation limited to a specific oral health problem or complaint. This may require interpretation of information acquired through additional diagnostic procedures. Report additional diagnostic procedures separately. Definitive procedures may be required on the same date as the evaluation. Typically, patients receiving this type of evaluation present with a specific problem and/or dental emergencies, trauma, acute infections, etc.”

Some doctors perform a procedure at a visit, but erroneously report this procedure as a problem-focused limited oral evaluation (D0140). D0140 is an oral evaluation code, not a treatment code.

Understanding D9110: Palliative Treatment

If a procedure without a distinct code was performed due to discomfort, sensitivity, or pain as reported by the patient, D9110 may be reported. In some cases, D9110 and D0140 may not be reimbursed if reported on the same service date. Likewise, the problem-focused oral evaluation (D0140) may be denied if reported on the same service date that definitive treatment is performed. However, D0140 is a stand-alone code and may be reported in addition to any other treatment procedures rendered on the same service date, i.e., extraction, filling, or palliative (D9110), etc., but remember the reimbursement is subject to the plan’s limitations. 

D9110 is a highly underutilized code! Consider reporting D9110 for minor procedures to reduce discomfort, sensitivity, or pain at an emergency visit so as not to trigger the evaluation frequency limitation established by most plans. 

Key Reporting Requirements for D9110

The key concepts required for accurate reporting of D9110 are that it: 

1. Must alleviate a patient’s pain or discomfort. 
2. Must be initiated by the patient 
3. Must not be curative in nature 
4. Must not be a definitive procedure that would be more appropriately reported with its own code, as determined by the treating dentist 
5. May or may not be an emergency visit.

Evaluation vs Treatment: Why the Distinction Matters

A problem-focused oral evaluation (D0140) is an evaluation, while palliative (D9110) is a treatment. Palliative treatment is always initiated by the patient, whether at an emergency visit or any other visit.

The problem-focused oral evaluation (D0140) or any other evaluation is generally limited by the “one evaluation per six months” or “two evaluations per year” exclusion. Oral evaluations are stand-alone and may be reported in conjunction with D9110. However, some payors will not reimburse an oral evaluation in conjunction with D9110 if performed on the same service date. The payment of an oral evaluation would generally be subject to frequency limitations. 

Documentation Requirements for D9110

Palliative (D9110) always requires clinical documentation in order to receive consistent reimbursement, even though it is not a “by report” code. Always submit a narrative or chart notes, reporting “what you do,” with full disclosure regarding the reporting of D9110.

Always mention the tooth number or area of mouth, if applicable. The documentation, if applicable, should state “patient will return for more definitive treatment.” This indicates definitive treatment was not performed during the palliative visit.

Remember that “Remarks” in Box 35 on the electronic claim should not include more than 80 characters, including punctuation and spaces, to guarantee that the full narrative is received by the payor.

Additional Resources for Accurate Coding

Additional tips regarding proper reporting for D0140 and the many uses of D9110 can be found in Practice Booster’s Dental Coding With Confidence or their online Code Advisor! 

If you are struggling with CDT coding, consider partnering with eAssist. Our Success Consultants have full access to the entire Practice Booster library to support you in coding for what you actually do as documented in the patient’s clinical record. To find out more, schedule a free consultation here.

Disclaimer: Insurance administration and dental billing recommendations presented here represent the opinions of the author or our staff and are for informational purposes only. You are responsible for your own use of the CDT Codes, insurance administration, and dental billing. For the latest CDT codes and official interpretations, contact the American Dental Association or visit ADA.org.