CPT 97110: A Guide to Billing for Therapeutic Exercise

You likely use CPT 97110 Therapeutic Exercise in every session. Because it's so commonly used in rehab, many payers highly scrutinize the documentation before approving for reimbursement. Keep reading to learn what you should include in your documentation of CPT 97110.

Everything You Need to Know About CPT Code 97110 for PT

CPT Code 97110 is a physical therapy billing code that covers therapeutic exercises designed to develop strength, endurance, range of motion, and flexibility. This time-based code is billed in 15-minute units and requires direct patient contact with a qualified healthcare provider. Healthcare providers, billing professionals, and practice administrators need to understand proper usage, billing requirements, and documentation standards for CPT 97110 to ensure accurate reimbursement and regulatory compliance.

Understanding CPT 97110: Definition and When to Use It

CPT Code 97110 is officially defined by the American Medical Association (AMA) as “Therapeutic procedure, 1 or more areas, each 15 minutes; therapeutic exercises to develop strength and endurance, range of motion and flexibility.” This code covers exercises that target physical impairments and functional limitations through structured, progressive activities.

Time-Based Requirements and Direct Contact

The code operates on a 15-minute unit basis, requiring direct one-on-one patient contact with a qualified provider. Each billable unit represents a minimum of 8 minutes of direct therapeutic exercise intervention. The provider must actively guide, instruct, or assist the patient throughout the treatment session.

Qualifying Exercise Types

CPT 97110 covers four primary categories of therapeutic exercises:

• Strength training exercises – Progressive resistance activities using weights, bands, or body weight
• Endurance training – Cardiovascular and muscular endurance activities
• Range of motion exercises – Active, active-assisted, or resistive ROM activities
• Flexibility training – Stretching and mobility exercises to improve tissue extensibility

Clinical Applications

This code applies across numerous clinical scenarios where therapeutic exercise is medically necessary:

• Post-surgical rehabilitation – Recovery following orthopedic, cardiac, or neurological procedures
• Chronic pain management – Exercise-based interventions for persistent musculoskeletal conditions
• Neurological conditions – Motor retraining and strengthening for stroke, spinal cord injury, or traumatic brain injury
• Sports injury recovery – Structured return-to-activity programs following athletic injuries
• Age-related decline – Functional maintenance and improvement programs for older adults

Activities That Qualify vs. Don’t Qualify

Qualifying activities include supervised exercises with specific therapeutic goals, progressive resistance training, functional movement patterns, and condition-specific exercise protocols. Non-qualifying activities include general fitness training, unsupervised exercise, passive modalities without active exercise components, and activities that don’t address specific impairments or functional limitations.

How to Bill CPT 97110 Correctly: Rules and Documentation

Proper billing for CPT 97110 requires strict adherence to Medicare’s 8-minute rule and comprehensive documentation standards. Understanding these requirements prevents claim denials and ensures compliance with federal regulations.

8-Minute Rule Unit Calculations

The 8-minute rule determines how many units can be billed based on total treatment time. This calculation is critical for accurate billing and revenue optimization.

Total Treatment Time	Billable Units	Example
8-22 minutes	1 unit	15-minute strength training session
23-37 minutes	2 units	30-minute combined strength and ROM program
38-52 minutes	3 units	45-minute comprehensive exercise session
53-67 minutes	4 units	60-minute intensive rehabilitation program
68-82 minutes	5 units	Extended therapy session with multiple exercise types

Required Documentation Elements

Comprehensive documentation must include specific elements to support medical necessity and billing accuracy:

• Body part identification – Specific anatomical regions being treated
• Exercise type specification – Detailed description of therapeutic activities performed
• Functional goals – Clear connection between exercises and functional outcomes
• Medical necessity justification – Clinical rationale linking exercises to patient’s condition
• Patient response and progress – Objective measures of improvement or tolerance
• Time documentation – Accurate recording of direct contact time for unit calculation

Medical Necessity and Goal Linking

All therapeutic exercises must demonstrate clear medical necessity through established functional goals. Documentation should explicitly connect each exercise to specific impairments, activity limitations, or participation restrictions identified in the initial evaluation.

Common Billing Errors and Prevention

Frequent billing mistakes include incorrect unit calculations, insufficient documentation of medical necessity, billing for non-qualifying activities, and failure to demonstrate skilled intervention. Prevention strategies include regular staff training, documentation audits, and implementation of standardized treatment protocols.

Medicare vs. Commercial Payer Differences

Medicare follows strict 8-minute rule calculations and requires detailed medical necessity documentation. Commercial payers may have varying requirements for prior authorization, frequency limitations, or alternative documentation standards. Providers should verify specific payer policies before treatment initiation.

CPT 97110 vs Similar Codes: Key Differences and Reimbursement Rates

Understanding how CPT 97110 differs from similar codes and current reimbursement rates is essential for proper billing practices and financial planning.

CPT 97110 vs. 97530 Key Differences

The distinction between therapeutic exercises (97110) and therapeutic activities (97530) is crucial for proper code selection:

Criteria	CPT 97110 (Therapeutic Exercise)	CPT 97530 (Therapeutic Activities)
Primary Focus	Strength, endurance, ROM, flexibility	Functional task-specific activities
Exercise Type	Component-based exercises	Integrated functional movements
Equipment	Exercise equipment, weights, bands	Real-world objects and environments
Patient Participation	Active participation in structured exercises	Dynamic participation in functional tasks
Clinical Examples	Resistance training, stretching, cardio	Simulated work tasks, ADL training

Common Code Pairings and NCCI Considerations

CPT 97110 frequently pairs with other physical therapy codes such as 97140 (manual therapy), 97112 (neuromuscular reeducation), and evaluation codes. National Correct Coding Initiative (NCCI) edits may restrict certain code combinations, requiring modifier 59 for appropriate separate billing when services are distinct and medically necessary.

Current Medicare Reimbursement Rates

Medicare reimbursement for CPT 97110 varies by geographic location and practice setting. The 2024 Medicare Physician Fee Schedule shows national average rates ranging from $28-35 per unit for facility settings and $35-42 per unit for non-facility settings. Commercial insurance rates typically range 10-30% higher than Medicare rates, depending on contract negotiations and regional market factors.

Modifier 59 Usage Guidelines

Modifier 59 (Distinct Procedural Service) may be required when billing CPT 97110 with other therapy codes during the same session. This modifier indicates that services were provided to different body parts, during separate encounters, or represent distinctly different procedures not typically performed together.

Geographic Payment Variations

Reimbursement rates vary significantly based on geographic practice cost indices (GPCI). Urban areas with higher practice costs typically receive higher reimbursement rates, while rural areas may have lower rates. Providers should consult their local Medicare Administrative Contractor for specific regional rates.

Final Thoughts

CPT Code 97110 represents a fundamental component of physical therapy billing, requiring precise understanding of clinical applications, billing rules, and documentation requirements. Proper implementation of the 8-minute rule, comprehensive documentation practices, and accurate code differentiation are essential for maximizing appropriate reimbursement while maintaining regulatory compliance.

Healthcare providers must stay current with evolving billing requirements, payer policy changes, and documentation standards to ensure successful claims processing. Regular training, internal audits, and systematic documentation practices help prevent common billing errors and support optimal patient care delivery.

For rehabilitation professionals seeking to enhance their therapeutic exercise programs and billing accuracy, specialized resources and equipment solutions can provide valuable support. Companies like BTE offer comprehensive rehabilitation equipment and assessment tools that can help optimize CPT 97110 service delivery while ensuring proper documentation and billing compliance.

 

 

Bennett Richardson, PT, DPT, CSCS

Bennett Richardson, PT, DPT, CSCS is a Physical Therapist and writer. He is the owner of Richardson PT LLC, a mobile, cash-based physical therapy service out of Pittsburgh, PA. Ben is passionate about many health-related topics including weight loss and athletic performance. To get in touch with Ben, visit www.richardsonpt.com

References

1. American Physical Therapy Association (APTA). (2018). Guide to Physical Therapist Practice. 3rd ed.
2. Centers for Medicare & Medicaid Services (CMS). (2019). Medicare Claims Processing Manual. Chapter 5 – Part B Outpatient Rehabilitation and CORF/OPT Services. Section 20.2 – Components of a Therapy Service. https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Internet-Only-Manuals-IOMs-Items/CMS018912 
3. Dutton, M. (Ed.). (2012). Dutton’s Orthopaedic Examination, Evaluation, and Intervention. 3rd ed. https://openlibrary.org/books/OL25163122M/Orthopaedic_examination_evaluation_and_intervention 
4. Hertling, D., & Kessler, R. M. (2006). Management of Common Musculoskeletal Disorders: Physical Therapy Principles and Methods. 4th ed.
5. Kisner, C., & Colby, L. A. (2013). Therapeutic Exercise: Foundations and Techniques. 6th ed. ISBN-13: 978-0-8036-2574-7