CPT code 97110: Therapeutic exercise billing guide

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Key takeaways

CPT code 97110 covers therapeutic exercise for strength, endurance, range of motion, and flexibility, performed with direct one-on-one patient contact.

Billing is time-based, with one unit equal to 15 minutes. Medicare’s 8-minute rule decides whether a partial unit is payable.

Thin documentation is the top denial trigger. Every note needs the diagnosis, treatment goals, time spent, patient response, and the therapist’s signature.

Billing 97110 alongside 97112 or 97140 needs modifier 59 or XS, plus notes that separate the two services.

Practice management software like Pabau calculates time-based units automatically and flags incomplete documentation before a claim reaches the payer.

CPT code 97110 bills therapeutic exercise in 15-minute units, covering work on strength, endurance, range of motion, and flexibility. It is one of the most reported physical medicine codes in outpatient therapy, and a recurring focus of payer and OIG review. Denials cluster around the note rather than the code: missing time stamps, no functional goal, or a session that reads like group therapy.

This guide walks through the official descriptor, who may bill it, and what each claim has to document. It then shows how the 8-minute rule sets the unit count. The 2026 Medicare rate and the NCCI edits that pair 97110 with other timed codes follow. All of it sits inside the wider medical billing workflows a therapy practice runs.

CPT code 97110: definition and official description

CPT code 97110 describes therapeutic exercise performed to develop strength, endurance, range of motion, and flexibility. The American Medical Association publishes the official descriptor. “Therapeutic procedure, one or more areas, each 15 minutes; therapeutic exercises to develop strength and endurance, range of motion and flexibility.”

Two elements govern whether the code holds up. First, the exercise runs under direct one-on-one patient contact, so the treating therapist is present and actively engaged rather than supervising from across the room. Second, the service is time-based, and each unit represents 15 minutes of that hands-on exercise.

• Strength training: Progressive resistance exercises targeting specific muscle groups
• Endurance training: Cardiovascular or sustained-effort activities with a therapeutic goal
• Range of motion: Passive, active-assistive, or active stretching to restore joint mobility
• Flexibility: Targeted stretching programs to address soft-tissue restriction

The line between 97110 and CPT 97530 (therapeutic activities) sits in the nature of the exercise. Code 97110 covers rote, repetitive exercise aimed at one physical parameter. Code 97530 covers dynamic, functional activity that simulates a task from daily life or work. Billing the wrong one for the session type is the audit trigger practices hit most often.

Who can bill CPT 97110?

Physical therapists and occupational therapists bill CPT code 97110 directly, and physical therapist assistants bill it at a reduced Medicare rate. Beyond those three, eligibility follows scope-of-practice rules that differ by state, so check your license law and your payer contract first. Practices running multi-provider teams get help here from occupational therapy software that sets billing permissions by role.

In states with direct access laws, a physical therapist can bill without a physician referral. Requirements vary enough that a worked example helps, so review physical therapy clinic requirements to see how licensing and billing intersect in one state.

Documentation requirements for CPT 97110

Documentation failures are the leading cause of 97110 denials on audit. Guidance from the AAPC is blunt about the standard: every claim needs a clinical note that independently justifies each element billed. Meeting physiotherapy compliance requirements means building those elements into the session note, not reconstructing them weeks later.

• Diagnosis: The ICD-10-CM code(s) establishing medical necessity for therapeutic exercise
• Functional goals: Measurable, time-bound treatment goals directly tied to the exercises performed
• Treatment performed: Specific exercises, sets, reps, resistance levels, or duration – not just “therapeutic exercise”
• Time: Start and stop times, or total timed minutes, for each CPT code billed during the session
• Patient response: Objective measure of how the patient tolerated treatment and any modifications made
• One-on-one contact: A clear statement that the therapist provided direct patient contact throughout
• Therapist signature: Dated signature (or credentials and date for electronic records)

One nuance trips up practices repeatedly. The note has to reflect the exercises performed in that session, not carry forward text from the last visit. Copy-forward documentation is a primary OIG audit flag on physical therapy claims.

How to bill CPT 97110: units, time rules, and the 8-minute rule

CPT code 97110 is a time-based code. One unit equals 15 minutes of direct therapeutic exercise. For sessions that do not land on a clean 15-minute multiple, Medicare’s 8-minute rule determines how many units to bill. Understanding this rule prevents both underbilling and overpayment risk.

The 8-minute rule explained

Section 20.2 of the Medicare Claims Processing Manual, Chapter 5, sets the threshold. A timed service needs at least 8 minutes of direct contact to bill one unit. Past a full 15-minute unit, the leftover minutes have to reach 8 before they count as another unit.

Sessions with more than one timed code work differently. Say you bill 97110 and 97112 on the same day. Total timed minutes are added across both codes before units are allocated, then distributed proportionally and documented per code.

Unit caps and medical necessity

Medicare sets no universal per-visit unit cap for 97110. Coverage rests on medical necessity and documentation rather than a fixed daily limit. Many Medicare Administrative Contractors (MACs) and commercial payers do publish Local Coverage Determinations (LCDs) with typical unit ranges by diagnosis. Billing well above those ranges without strong notes invites a prepayment review, which is worth planning for when launching a physiotherapy clinic.

CPT 97110 vs 97530 vs 97112: which code to bill?

Choosing between 97110, 97530, and 97112 comes down to the clinical purpose of the session. Each code covers a distinct therapeutic concept, so the choice drives both what gets paid and how much audit exposure the claim carries.

Can 97110 and 97112 be billed on the same day? Yes, but only with a modifier. The two codes are an NCCI procedure-to-procedure edit pair, so a claim carrying both without a modifier loses the second code. Append modifier 59, or the more specific XS, and document separate time blocks and a distinct impairment for each code.

The 97110 and 97140 pairing works the same way. NCCI treats manual therapy as integral to therapeutic exercise. Billing both takes modifier 59 or XS, plus notes showing the two services addressed different body regions. Manual therapy and exercise on the same shoulder stays bundled, whatever modifier you append. The summary below sorts the four pairings a therapist runs into most.

Medicare reimbursement rates for CPT code 97110 in 2026

CPT code 97110 is paid per 15-minute unit under the Medicare Physician Fee Schedule (MPFS). The national average moves every January, and 2026 changed how that figure is built. Submitting electronic claims via Claim.MD keeps eligibility responses and remittance data in one place, so rate discrepancies surface before they become write-offs.

The 2026 figure comes from two numbers. CMS finalized a conversion factor of $33.5675 for qualifying alternative payment model participants and $33.4009 for everyone else in the CY2026 fee schedule final rule. Multiplied by the non-facility relative value units for 97110, that lands a shade under $30 per unit before any geographic adjustment.

Look up your own locality before you model revenue on it. The CMS Physician Fee Schedule search tool returns the allowed amount for a specific ZIP code and place of service. Then read the electronic remittance advice against that number to catch quiet underpayments.

Common billing errors that trigger 97110 denials

The OIG has repeatedly flagged physical therapy billing as a high-risk area for overpayments. On 97110 specifically, the errors that reliably trigger a denial fall into five patterns. Managing claim denials starts with recognizing them before they turn into payer disputes.

• Generic documentation: Notes that say “therapeutic exercise performed” without specifying exercises, sets, resistance, or time. Every payer expects the note to paint a picture of what actually happened.
• Billing 97110 for group therapy: Treating more than one patient at the same time is group therapy (CPT 97150). Identical exercises do not change that. Code 97110 requires dedicated one-on-one time.
• Misuse of 97110 vs 97530: Billing 97110 for a session that was functionally oriented (simulated ADLs, job tasks, sport-specific movements) instead of 97530. Payer audits find this pattern quickly.
• 8-minute rule errors: Rounding up time to claim an extra unit when the remaining minutes fall below 8. This is a direct overpayment and one of the easiest errors for a payer to detect.
• Missing functional goals: Treatment without documented, measurable goals tied to the patient’s functional deficits. Medicare explicitly requires goal-oriented documentation for coverage.

Practices focused on submitting clean claims build validation into the billing workflow itself. That catches these errors before the claim leaves the building, rather than unwinding them through appeal.

How practice management software helps with 97110 billing compliance

Missing documentation and time-based billing errors are workflow problems as much as clinical ones. When therapists chart by hand between patients, required fields get skipped. When billing staff count units off handwritten time logs, small calculation errors compound across a month.

Pabau’s claims management software ties clinical documentation to billing. Time stamps recorded in the session note calculate the timed units for a 97110 claim automatically.

Required fields can be set as mandatory inside SOAP note templates, so a claim cannot go out with missing treatment time or an unsigned note. That keeps the session record and the submitted claim describing the same visit.

For teams running PT, OT, and rehab side by side, Pabau’s physical therapy EMR holds billing and documentation in one platform. That removes the manual handoffs where coding errors creep in. The built-in physiotherapy clinic management reporting tracks denial trends by code, so you can see whether 97110 claims from one provider or payer are underperforming.

Stop losing revenue to preventable billing errors

Pabau calculates time-based units for codes like CPT 97110 and flags incomplete documentation before claims go out. It connects to clearinghouses too, so your practice gets paid faster.

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Conclusion

CPT code 97110 is simple to describe and easy to bill wrong. The distance between a paid claim and a denied one usually sits in the note. Look for missing time stamps, a generic exercise description, or a session that should have been 97530. The pairing rules cost practices just as much, since 97112 and 97140 each need a modifier alongside 97110.

Fix the documentation habit first and the unit math second. A note template that forces start and stop times at the point of care removes most of the denial risk here. Once configured, it costs nothing to enforce. Our physical therapy EMR counts the units from that note and holds the claim until it is signed. Book a demo to see that workflow run on your own claim data.

Continue your research

Need guidance on physiotherapy compliance in your state? Physiotherapy compliance requirements breaks down the regulatory obligations physical therapy practices must meet to stay audit-ready.

Exploring software for your rehab practice? Physiotherapy clinic management software covers what to look for in a platform that supports both documentation and billing workflows.

Want to understand the full revenue cycle context? What is revenue cycle management explains how individual CPT codes like 97110 fit into the broader financial flow of a healthcare practice.

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