Therapeutic exercises
CPT code 97110 covers therapeutic exercises performed during physical therapy sessions to develop strength, endurance, flexibility, or range of motion. This is the most commonly billed physical therapy treatment code.
RVU breakdown
Conversion factor: 32.3465 · Source: CMS MPFS RVU25A · Confidence: High
Billing tips
Use 8-minute rule correctly: 8-14 minutes = 1 unit, 23-37 minutes = 2 units, 38-52 minutes = 3 units
Impact: Incorrect unit calculation is the #1 cause of 97110 overpayment recoveries, averaging $3,500 per audit
Document specific exercises performed (e.g., '3 sets of 10 squats, theraband resistance exercises') not just 'therapeutic exercises'
Impact: Generic documentation increases audit risk by 340% and denial rate by 28%
Do not bill 97110 for the same body part/goal as 97112 in same session without modifier 59 and distinct documentation
Impact: Bundling edits will reduce payment; proper separation can preserve $28.79 per additional unit
Bill separately from evaluation codes (97161-97163) on same day; no modifier needed
Impact: Ensures full reimbursement for both services, protecting $56-$112 in evaluation fees
Track total therapy dollars year-to-date for Medicare patients to anticipate KX modifier needs at $2,230 threshold
Impact: Proactive KX modifier use prevents $28.79 denials for every unit over threshold
Ensure one-on-one documentation for constant attendance; group therapy (97150) pays less
Impact: 97150 pays only $7.20 vs $28.79 for individual 97110, a $21.59 difference per unit
Common denials
Insufficient documentation of medical necessity or functional goals
How to appeal: Submit complete plan of care with measurable goals, baseline function scores (e.g., LEFS, DASH), and progress notes showing objective improvement. Reference LCD L33622 requirements.
8-minute rule violation - units billed exceed documented time
How to appeal: Provide corrected claim with accurate unit calculation and detailed time log. If time was documented incorrectly, submit amended notes with attestation explaining documentation error vs. service error.
Denied as maintenance therapy or lack of skilled need
How to appeal: Demonstrate complexity requiring PT expertise, cite Jimmo v. Sebelius settlement allowing maintenance if skilled services needed, provide evidence patient cannot self-manage program safely
Missing or incorrect therapy modifier (GP/GO/GN)
How to appeal: Submit corrected claim with appropriate modifier within timely filing limits. Include attestation that service was provided under correct therapy discipline plan of care.
Frequently asked questions
How much does Medicare pay for CPT code 97110 in 2025?
Medicare pays $28.79 for CPT 97110 in 2025 (national average non-facility rate). The facility rate is also $28.79. Actual payment may vary by MAC locality, and patient coinsurance is typically 20% ($5.76).
How many units of 97110 can I bill per session?
There is no hard limit on units per session, but you must follow the 8-minute rule (8-22 minutes = 1 unit, 23-37 minutes = 2 units, etc.). Most sessions bill 2-4 units. Consistently billing 6+ units daily may trigger audit flags for medical necessity review.
What is the 8-minute rule for CPT 97110?
The 8-minute rule determines units billed for timed codes. For 97110: 8-22 minutes = 1 unit, 23-37 minutes = 2 units, 38-52 minutes = 3 units. You must reach the midpoint (8 minutes for first unit, 15 minutes for each additional) to bill each unit.
Can 97110 and 97112 be billed together on the same day?
Yes, but they must address different functional goals or body regions with distinct documentation for each. Use modifier 59 on the second code if needed to prevent bundling. Document clearly how 97110 (exercises) differs from 97112 (neuromuscular reeducation) in your treatment approach.
What documentation is required to bill CPT 97110?
Required documentation includes: timed minutes spent on 97110, specific exercises performed (sets/reps/resistance), body parts treated, patient response, progress toward goals, therapist signature/credentials, and confirmation of one-on-one direct contact. Generic terms like 'therapeutic exercises performed' are insufficient.
Does CPT 97110 require a physician referral?
Medicare and most payers require a physician referral or plan of care certification for physical therapy services including 97110. Some states allow direct access to PT without referral for commercial insurance, but Medicare always requires physician certification within 30 days of initial service.
What is the RVU for CPT code 97110?
CPT 97110 has a total RVU of 0.89 for 2025 (Work RVU: 0.45, PE RVU: 0.43, MP RVU: 0.01). This is multiplied by the conversion factor of 32.3465 to calculate the $28.79 Medicare payment rate.