Billing Coding/Physician Documentation Information
97110 Therapeutic procedure, 1 or more areas, each 15 minutes; therapeutic exercises to develop strength and endurance, range of motion and flexibility
97112 Therapeutic procedure, 1 or more areas, each 15 minutes; neuromuscular reeducation of movement, balance, coordination, kinesthetic sense, posture, and/or proprioception for sitting and/or standing activities
97113 Therapeutic procedure, 1 or more areas, each 15 minutes; aquatic therapy with therapeutic exercises
97116 Therapeutic procedure, 1 or more areas, each 15 minutes; gait training (includes stair climbing)
97124 Therapeutic procedure, 1 or more areas, each 15 minutes; massage, including effleurage, petrissage and/or tapotement (stroking, compression, percussion)
97139 Unlisted therapeutic procedure (specify)
Counting Minutes for Timed Codes in 15 Minute Units
When only one service is provided in a day, providers should not bill for services performed for less than 8 minutes. For any single timed CPT code in the same day measured in 15 minute units, providers bill a single 15-minute unit for treatment greater than or equal to 8 minutes through and including 22 minutes. If the duration of a single modality or procedure in a day is greater than or equal to 23 minutes, through and including 37 minutes, then 2 units should be billed. Time intervals for 1 through 8 units are as follows:
Units Number of Minutes
1 unit: = 8 minutes through 22 minutes
2 units: = 23 minutes through 37 minutes
3 units: = 38 minutes through 52 minutes
4 units: = 53 minutes through 67 minutes
5 units: = 68 minutes through 82 minutes
6 units: = 83 minutes through 97 minutes
7 units: = 98 minutes through 112 minutes
8 units: = 113 minutes through 127 minutes
The pattern remains the same for treatment times in excess of 2 hours.
If a service represented by a 15 minute timed code is performed in a single day for at least 15 minutes, that service shall be billed for at least one unit. If the service is performed for at least 30 minutes, that service shall be billed for at least two units, etc. It is not appropriate to count all minutes of treatment in a day toward the units for one code if other services were performed for more than 15 minutes. See examples 2 and 3 below.
When more than one service represented by 15 minute timed codes is performed in a single day, the total number of minutes of service (as noted on the chart above) determines the number of timed units billed. See example 1 below.
If any 15 minute timed service that is performed for 7 minutes or less than 7 minutes on the same day as another 15 minute timed service that was also performed for 7 minutes or less and the total time of the two is 8 minutes or greater than 8 minutes, then bill one unit for the service performed for the most minutes. This is correct because the total time is greater than the minimum time for one unit. The same logic is applied when three or more different services are provided for 7 minutes or less than 7 minutes. See example 5 below.
The expectation (based on the work values for these codes) is that a provider’s direct patient contact time for each unit will average 15 minutes in length. If a provider has a consistent practice of billing less than 15 minutes for a unit, these situations should be highlighted for review.
If more than one 15 minute timed CPT code is billed during a single calendar day, then the total number of timed units that can be billed is constrained by the total treatment minutes for that day. See all examples below.
Pub. 100-02, Medicare Benefit Policy Manual, Chapter 15, Section 220.3B, Documentation Requirements for Therapy Services, indicates that the amount of time for each specific intervention/modality provided to the patient is not required to be documented in the Treatment Note. However, the total number of timed minutes must be documented. These examples indicate how to count the appropriate number of units for the total therapy minutes provided.
Example 1 –
24 minutes of neuromuscular reeducation, code 97112,
23 minutes of therapeutic exercise, code 97110,
Total timed code treatment time was 47 minutes.
See the chart above. The 47 minutes falls within the range for 3 units = 38 to 52 minutes.
Appropriate billing for 47 minutes is only 3 timed units. Each of the codes is performed for more than 15 minutes, so each shall be billed for at least 1 unit. The correct coding is 2 units of code 97112 and one unit of code 97110, assigning more timed units to the service that took the most time.
Example 2 –
20 minutes of neuromuscular reeducation (97112)
20 minutes therapeutic exercise (97110),
40 Total timed code minutes.
Appropriate billing for 40 minutes is 3 units. Each service was done at least 15 minutes and should be billed
for at least one unit, but the total allows 3 units. Since the time for each service is the same, choose either
code for 2 units and bill the other for 1 unit. Do not bill 3 units for either one of the codes.
Example 3 –
33 minutes of therapeutic exercise (97110),
7 minutes of manual therapy (97140),
40 Total timed minutes
Appropriate billing for 40 minutes is for 3 units. Bill 2 units of 97110 and 1 unit of 97140. Count the first 30 minutes of 97110 as two full units. Compare the remaining time for 97110 (33-30 = 3 minutes) to the time spent on 97140 (7 minutes) and bill the larger, which is 97140.
Example 4 –
18 minutes of therapeutic exercise (97110),
13 minutes of manual therapy (97140),
10 minutes of gait training (97116),
8 minutes of ultrasound (97035),
49 Total timed minutes
Appropriate billing is for 3 units. Bill the procedures you spent the most time providing. Bill 1 unit each of 97110, 97116, and 97140. You are unable to bill for the ultrasound because the total time of timed units that can be billed is constrained by the total timed code treatment minutes (i.e., you may not bill 4 units for less
than 53 minutes regardless of how many services were performed). You would still document the ultrasound in the treatment notes.
Example 5 –
7 minutes of neuromuscular reeducation (97112)
7 minutes therapeutic exercise (97110)
7 minutes manual therapy (97140)
21 Total timed minutes
Appropriate billing is for one unit. The qualified professional (See definition in Pub. 100-02, chapter 15, section 220) shall select one appropriate CPT code (97112, 97110, 97140) to bill since each unit was performed for the same amount of time and only one unit is allowed.
NOTE: The above schedule of times is intended to provide assistance in rounding time into 15-minute increments. It does not imply that any minute until the eighth should be excluded from the total count. The total minutes of active treatment counted for all 15 minute timed codes includes all direct treatment time for
the timed codes. Total treatment minutes – including minutes spent providing services represented by untimed codes – are also documented. For documentation in the medical record of the services provided see Pub. 100-02, chapter 15, section 220.3.
Therapeutic Procedures
Therapeutic Procedures (codes 97110-97546) were added to CPT® in 1995 to clarify the differences between Therapeutic Procedures, Modalities, and Tests and Measurements. A Therapeutic Procedure is defined as “a manner of effecting change through the application of clinical skills and/or services that attempt to improve function.” These procedures require direct one-on-one patient contact by a physician or therapist. The descriptions for most of these codes reflect 15-minute intervals.
Common components included as part of Therapeutic Procedures include chart reviews for treatment, setup of activities and the equipment area, and review of previous documentation as needed. Subsequent to providing the therapeutic service, the treatment is recorded, and the patient’s progress is documented. The patient health record should list the duration of the procedure time.
Therapeutic Procedures are intended to be performed with one-on-one patient contact. If a provider is performing Therapeutic Procedures in a group of two or more individuals, CPT® code 97150 should be reported. Time and/or the number of Therapeutic Procedures are not specified in this code so it should only be billed once per patient per visit.
To illustrate, a practitioner spends 10 minutes working with patient X on therapeutic exercises to develop strength and endurance. The practitioner instructs patient X to continue the exercises for 5 or more minutes and attends to another patient, patient Y, during this time, while continuing to supervise patient X. The practitioner returns to patient X and spends another 5 minutes directly working with him, and once again instructs patient X to continue a particular exercise for 5 minutes. The practitioner again attends to patient Y during this time, and then returns to patient X to work directly with him for another 5 minutes. Should code 97150 be reported, or should code 97110 be reported twice**
From a CPT coding perspective, code 97110 requires the practitioner to maintain direct patient contact (i.e., visual, verbal, and/or manual contact) during provision of the service, so 97110 should only be reported when the practitioner is providing therapy to one patient alone. When the practitioner is working with several patients at the same time, then CPT code 97150 should be reported. The specific type of therapy provided (e.g., 97110) to the group therapy code.
What is considered a unit of time when reporting time based codes**
A Review of Reporting Time-Based Codes:
“According to the codebook’s instruction, a unit of time is attained when the mid-point is passed. For example, an hour is attained when 31 minutes have elapsed (more than midway between zero and sixty minutes) When codes are ranked in sequential typical times and the actual time is between two typical times, the code with the typical time closest to the actual time is used (CPT 2014; page xv).Therefore …based on the time guidelines provided in the CPT code set, it is not appropriate to append modifier 52, Reduced Services, to codes 97110-97546. Services of less than eight minutes would not be reported. To illustrate further, when reporting Physical Medicine and Rehabilitation code 97110, a time-based code can be reported for each 15-minute unit. Multiple units can be reported on a date of service for one or more
procedures based on the aggregate amount of time spent by a qualified health care professional in direct contact with the patient. As with any 15-minute time based code, it is important to recognize that a substantial portion of the 15 minutes must be spent in performing the pre-, intra-, and post service work in order to report the time-based code. If only five minutes are spent performing the physical medicine service, the code should not be reported. A minimum of eight minutes of therapeutic exercises is required to report code 97110.”
Medicare Guidelines for Timed Codes:
Medicare guidelines are different from the above in that providers should report the code for the time actually spent in delivery of the modality requiring constant attendance and therapy services. Pre- and post-delivery services are not to be counted in determining the treatment service time. In other words, the time counted as “intraservice care” begins when the therapist, physician, or assistant under the supervision of a physician, is delivering treatment services. The patient should already be in the treatment area (e.g., on the treatment table or mat or in the gym) and prepared to begin treatment.
The time counted is the time the patient is treated. For example, if gait training for a patient with a recent stroke requires both a therapist and an assistant, or even two therapists to manage the patient on the parallel bars, each 15 minutes the patient is being treated counts as one unit of 97116. The time the patient spends not being treated because of the need for toileting or resting should not be billed. In addition, the time spent waiting to use a piece of equipment or for other treatment to begin is not considered treatment time.
For any single CPT® code, providers would bill Medicare a single 15-minute unit for treatment greater than or equal to 8 minutes and less than 23 minutes. If the duration of a single modality or procedure is greater than or equal to 23 minutes to less than 38 minutes, then 2 units should be billed. Time intervals for larger numbers of units are as follows:
3 units > 38 minutes to < 53 minutes
4 units > 53 minutes to < 68 minutes
5 units > 68 minutes to < 83 minutes
6 units > 83 minutes to < 98 minutes
7 units > 98 minutes to < 113 minutes
8 units > 113 minutes to < 128 minutes
The pattern remains the same for treatment times in excess of 2 hours. Providers should not bill for services performed for less than 8 minutes. The expectation (based on the work values for these codes) is that a provider’s time for each unit will average 15 minutes in length. If a provider has a practice of billing less than 15 minutes for a unit, these situations should be highlighted for review.
The above schedule of times is intended to provide assistance in rounding time into 15-minute increments. It does not imply that any minute until the 8th should be excluded from the total count as the timing of active treatment counted includes all time.
It is advisable that the beginning and ending time of the treatment should be recorded in the patient’s medical record along with the note describing the treatment and patient’s progress. If more than one CPT code is billed during a calendar day, then the total number of units that can be billed is constrained by the total treatment time, see examples below.
Example 1: If 24 minutes of 97112 and 23 minutes of 97110 were furnished, then the total treatment time was 47 minutes, so only 3 units can be billed for the treatment. The correct coding is 2 units of 97112 and one unit of 97110, assigning more units to the service that took more time.
Example 2: If a therapist delivers 5 minutes of 97035 (ultrasound), 6 minutes of 97140 (manual techniques), and 10 minutes of 97110 (therapeutic exercise), then the total minutes are 21 and only one unit can be paid. Bill one unit of 97110 (the service with the longest time) and the clinical record will serve as documentation that the other two services were also performed.
QUICK GUIDE TO USING THE PTA MODIFIER with therapy procedures
Beginning January 1, 2020, CMS requires the use of the CQ modifier to denote outpatient therapy services furnished in whole or in part by a physical therapist assistant (PTA) in physical therapist (PT) private practices, skilled nursing facilities, home health agencies, outpatient hospitals, rehabilitation agencies, and comprehensive outpatient rehabilitation facilities. (A similar modifier, identified as CO, is required for services furnished by an occupational therapy assistant.)
Beginning January 1, 2022, these services will be paid at 85% of the Medicare physician fee schedule amount that is otherwise applicable.
Note: Check the policies for all your non-Medicare fee-for-service payers to determine if they will adopt use of the PTA modifier.
How to Use This Guide:
Use this guide to help you identify when you must apply the CQ modifier. When billing timed treatment codes, first determine the total number of units that can be billed based on the 8-minute rule. Then determine, for each unit, whether the PTA furnished more than 10% of each unit independent of the physical therapist. This is the de minimis standard that was established for determining “in part” services.
• Only the minutes the PTA spends independent of the PT count toward the 10% de minimis standard.
• The 10% de minimis standard is applied to untimed codes, and is applied to each billed unit of a timed code rather than to all billed units of a timed code.
• If a PTA’s time spent furnishing care exceeds 10% of the total time spent furnishing an untimed code, apply the CQ modifier.
• If a PTA’s time spent furnishing care exceeds 10% of a unit of service, apply the CQ modifier to the unit.
• If a PTA’s time spent furnishing care is 10% or less of a unit of the service, do not apply the CQ modifier.
DEFINITIONS
In whole: The entire service or procedure, or 100% of the total treatment time.
In part: Exceeds the de minimis portion of the therapy service, meaning more than 10% of the total service or procedure time when an untimed code. When a timed code, exceeds the de minimis standard of 10% of each billed unit.
DOCUMENTATION
CMS is not establishing any new documentation requirements to accompany the new CQ modifier. Current requirements for each treatment include all of the following:
• Date of treatment.
• Identification of each specific intervention provided and billed, for both timed and untimed codes, in language that can be compared with the billing on the claim to verify correct coding. You must record each service that is represented by a timed code, regardless of whether or not it is billed, because the unbilled timed services may impact the billing.
• Total timed code treatment minutes and total treatment time in minutes. Total treatment time includes the minutes for both timed and untimed code treatment; it does not include time for services that are not billable, such as rest periods. Medicare does not require recording of services that are neither billable nor part of the total treatment minutes, but you may choose to include them to provide an accurate description of the treatment, show consistency with the plan, or comply with state or local policies. You also may voluntarily record the amount of time for each specific intervention, but it isn’t required because it is indicated in the billing. The billing minutes must be consistent with the total timed code treatment minutes. (More: Medicare Claims Processing Manual, Pub 100-04, Chapter 5, Section 20.2)
• Signature and professional identification of the qualified provider(s) who furnished or supervised the services and a list of each person who contributed to that treatment—for example: signature of Kathleen Smith, PTA, with notation of phone consultation with Judy Jones, PT, supervisor [when such remote supervision is permitted by state and local law]. The supervisor’s signature and identification need not be on each treatment note unless the supervisor actively participated in the treatment. (More: Medicare Benefit Policy Manual Chapter 15, Section 220.3(E))
EXAMPLES
A. The PT and PTA each individually and exclusively furnish minutes of the same therapeutic exercise service (CPT 97110) in different time frames: The PT furnishes 7 minutes and the PTA furnishes 7 minutes, for a total of 14 minutes. One 15-minute unit is billed based on the total time range of at least 8 minutes and up to 22 minutes.
Billing:
• Report 1 unit of 97110 with the CQ modifier to signal that the PTA’s 7 minutes of furnished services exceeded 10% of the 1 unit of service, described in a 15-minute increment (1.5 rounded to 2 minutes, so the modifier would apply if the PTA had furnished 3 or more minutes of the service).
• The 7 minutes of 97110 furnished by the PT do not result in billable service. However, document them within the total treatment time.
NOTE: This results from a combination of factors: the same procedure is equally split between the 2 providers, only 1 unit can be billed, and the PTA has exceeded the de minimis standard.
B. The PT and PTA each individually and exclusively furnish minutes of the same therapeutic exercise service (CPT 97110) in different time frames: The PT furnishes 20 minutes and the PTA furnishes 25 minutes, for a total of 45 minutes. Three 15-minute units are billed based on the total time range of at least 38 minutes and up to 52 minutes.
Billing:
• Report 1 unit of 97110 without the CQ modifier, because the PT wholly furnished 1 unit of 97110 (20 minutes; within the 8-22 minute time range for a single unit).
• Report 2 units with CQ modifier, because the PTA wholly furnished 2 units of 97110 (25 minutes; within the 23-37 minute time range for 2 units).
C. The PTA and PT work concurrently as a team to furnish the same neuromuscular reeducation service (CPT 97112) for a 30-minute session. Two 15-minute units are billed based on the total time range of at least 23 minutes and up to 37 minutes.
Billing:
• Report 2 units of 97112 without the CQ modifier, because the PT furnished both units in whole while assisted by the PTA. The PTA’s time is irrelevant to billing.
D. The PT independently furnishes 15 minutes of manual therapy (CPT 97140), and then the PTA independently furnishes 7 minutes of therapeutic exercise (CPT 97110). One 15-minute unit of 97140 is billed based on the time range of at least 8 minutes and up to 22 minutes.
Billing:
• Report 1 unit of 97140 without the CQ modifier, because the PT furnished that service in whole.
• The 7 minutes of 97110 furnished by the PTA do not result in billable service. However, document them within the total treatment time.
E. Similar to Example D, but instead the PT independently furnishes 7 minutes of 97140, and the PTA independently furnishes 15 minutes of 97110. One 15-minute unit of 97110 is billed based on the time range of at least 8 minutes and up to 22 minutes.
Billing:
• Report 1 unit of 97110 with the CQ modifier, because the PTA furnished that service in whole.
• The 7 minutes of 97140 furnished by the PT do not result in billable service. However, document them within the total treatment time; and document the minutes for both codes and count them toward the total time of the timed code services furnished to the patient on the date of service.
F. Similar to Example D again, but instead the PT independently furnishes 7 minutes of 97140, and the PTA independently furnishes 7 minutes of 97110, for a total of less than a full 15 minutes. One 15-minute of service is billed based on the time range of at least 8 minutes and up to 22 minutes.
Billing:
• Report 1 unit of 97140 without the CQ modifier, because the PT furnished that service independently of the PTA; this is the “tie-breaker” when each provider furnishes the same number of minutes. The 7 minutes of 97110 furnished by the PTA do not result in billable service. However, document them within the total treatment time.
G. Similar to Example D again, but instead the PT furnishes 8 minutes of 97140, and the PTA furnishes 13 minutes of 97110. One 15-minute unit is billed based on the time range of at least 8 minutes and up to 22 minutes.
Billing:
• Report 1 unit of 97110 with the CQ modifier, consistent with CMS policy to bill the service with the greater time, and applying the modifier because the PTA furnished the service independently.
• The 8 minutes of 97140 furnished by the PT do not result in billable service. However, document them within the total treatment time.
H. The PT furnishes 20 minutes of neuromuscular reeducation (CPT 97112), and the PTA furnishes 8 minutes of 97110, for a total of 28 minutes. Two 15-minute units are billed based on the time range of at least 23 minutes and up to 37 minutes.
Billing:
• Report 1 unit of each procedure code, following the usual process for billing based on services furnished with the most minutes:
• Report 1 unit of 97112 without the CQ modifier.
• Report 1 unit of 97110 with the CQ modifier.
Note: This is because the 2 billable units of timed codes are allocated among procedure codes by assigning the first 15 minutes of service to 97112 (the code with the highest number of minutes), leaving 13 minutes of timed services: 5 minutes of 97112 (20 minus 15) and 8 minutes of 97110. Since the 8 minutes of 97110 is longer than the remaining 5 minutes of 97112, the second billable unit of service is assigned to 97110. The CQ modifier doesn’t apply to 97112 because the PT furnished all minutes of that service independently. The CQ modifier does apply to 97110 because the PTA furnished all minutes of that service independently.
I. The PT furnishes 32 minutes of 97112, the PT and PTA each separately furnish a combined 26 minutes of 97110 (12 minutes for the PT and 14 minutes for the PTA), and the PTA independently furnishes 12 minutes of self-care (CPT 97535), for a total of 70 minutes of timed code services. Five 15-minute units are billed based on the time range of at least 68 minutes and up to 82 minutes.
Billing:
• Report 2 units of 97112 without the CQ modifier, because the PT furnished the service in whole.
• Report 1 unit of 97110 without the CQ modifier, because the PT furnished 12 minutes independently.
• Report 1 unit of 97110 with the CQ modifier, because the PTA furnished 14 minutes independently.
• Report 1 unit of 97535 with the CQ modifier, because the PTA furnished the service in whole.
J. The PT independently furnishes 12 minutes of 97112, and the PTA independently furnishes 8 minutes of 97535 and 7 minutes of 97110, for a total time of 27 minutes. Two 15-minute units, 1 each of 97112 and 97535, are billed based on the time range of at least 23 minutes and up to 37 minutes.
Billing:
• Report 1 unit of 97112 without the CQ modifier, because the PT furnished it independently in whole.
• Report 1 unit of 97535 with the CQ modifier, because the PTA furnished it independently.
• The 7 minutes of 97110 do not result in billable service. However, document the minutes for all 3 codes and count them toward the total time of the timed code services furnished to the patient on the date of service.
K. The PT furnishes 15 minutes each of 97112 and 97535, and is assisted by the PTA, who furnishes 3 minutes of each service concurrently with the PT for a total time of 30 minutes. Two 15-minute units are billed based on the time range of at least 23 minutes and up to 37 minutes.
Billing:
• Report 1 unit of 97112 and 1 unit of 97535, both without the CQ modifier, because the PT furnished both units in whole while assisted by the PTA. The PTA’s time is irrelevant to billing. However, document that the PTA furnished 3 minutes of care alongside the therapist under 97112 and 3 minutes of care alongside the therapist under 97535. The time is not added to the total time.
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