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CPT 97110 therapeutic exercises code
CPT 97110 is used for therapeutic exercises to develop strength, endurance, range of motion, or flexibility. Documentation should support timed units, exercises performed, skilled need, patient response, diagnosis linkage, and payer therapy rules.
AMA maintains CPT, while CMS and payer therapy policies affect timed-unit documentation, modifiers, and reimbursement review.
- Therapeutic exercise service
- Timed unit documentation
- Skilled need and goal support
- Therapy modifier review
Official sources
What CPT 97110 Covers
CPT 97110 describes therapeutic exercises performed to develop strength, endurance, flexibility, and range of motion. This is a timed code billed in 15-minute increments, requiring direct one-on-one contact between the patient and a qualified healthcare provider. The code applies when exercises are prescribed by a physician or qualified practitioner and performed under direct supervision to address a specific functional deficit identified through examination.
Therapeutic exercises under 97110 are distinct from therapeutic activities (97530) and neuromuscular re-education (97112). The exercise must target specific muscle groups or physical parameters with the goal of restoring function lost due to injury, surgery, or disease. Common applications include post-surgical rehabilitation, injury recovery, chronic pain management, and functional restoration programs.
Billing Rules and Time Requirements
As a timed code, 97110 follows the 8-minute rule for Medicare billing. To bill one unit, the provider must deliver at least 8 minutes of the service. Two units require at least 23 minutes, three units require at least 38 minutes, and four units require at least 53 minutes. The total timed minutes across all timed codes in a session determine the billable units, not each code independently.
Medicare limits the total number of therapy units billable per day. The therapy cap, now implemented as a targeted review threshold, sits at $2,330 for physical therapy and speech-language pathology combined in 2026. Exceeding this threshold triggers manual review of claims but does not result in automatic denial. Documentation must justify the medical necessity of services exceeding the threshold.
The direct contact requirement means the provider must be working one-on-one with the patient during the billed time. Setting a patient up on a piece of equipment and walking away does not count toward 97110 time. The provider must actively instruct, supervise, and progress the exercises in real time. Group therapeutic exercise, if clinically appropriate, should be billed under 97150 instead of 97110.
Documentation Standards
Every 97110 session requires documentation that includes the specific exercises performed, the body part or muscle group targeted, the number of sets and repetitions or duration of each exercise, any resistance or equipment used, and the patient’s response to the intervention. This level of detail serves both clinical and billing purposes.
The plan of care must establish objective, measurable goals tied to functional outcomes. Goals like “improve strength” are insufficient. Instead, use measurable targets: “Increase left knee extension strength from 3/5 to 4/5 within 6 weeks to enable independent stair climbing.” Progress notes should reference these goals and document measurable changes at each visit.
Certified athletic trainers, physical therapy assistants (PTAs), and occupational therapy assistants (OTAs) can deliver 97110 services under appropriate supervision. The supervising therapist must co-sign notes and periodically re-evaluate the patient to update the plan of care. State practice acts determine specific supervision requirements.
Reimbursement Rates
Medicare reimbursement for 97110 in 2026 averages $32-$38 per unit (15 minutes) depending on geographic locality. This places 97110 among the higher-reimbursed therapy codes, reflecting the skill and direct contact required. A typical therapy session billing three units of 97110 generates $96-$114 in Medicare revenue.
Commercial payers reimburse $40-$65 per unit for 97110, with significant variation by payer and region. Workers’ compensation rates are generally higher, ranging from $45-$80 per unit. Practices should track reimbursement by payer to identify contracts where rates fall below the cost of delivery and negotiate improvements.
The revenue potential of 97110 depends on patient volume and clinical efficiency. A physical therapist seeing 10 patients per day and billing an average of 2.5 units of 97110 per session generates approximately $240-$320 in daily 97110 revenue at Medicare rates. Annual 97110 revenue per therapist typically ranges from $55,000 to $80,000, making it the highest-revenue therapy code for most rehabilitation practices.
Common Denial Reasons
The most frequent denial reason for 97110 is lack of medical necessity. Payers require documentation showing that the exercises address a specific functional limitation and that the patient is making measurable progress. Claims denied for medical necessity should be appealed with objective outcome data: range of motion measurements, strength tests, functional assessments, and documented goal achievement.
Billing errors create another category of denials. Common mistakes include billing 97110 and 97530 for the same time period (since both are timed codes, the total minutes must support the combined units), billing more units than the documented time supports, and using 97110 when the service is actually a maintenance program rather than skilled therapeutic intervention.
Prior authorization requirements vary by payer but are increasingly common for physical therapy services. Many commercial plans require authorization after an initial evaluation period (typically 8-12 visits). Missing authorization deadlines results in claim denials that are difficult to appeal. Front-desk staff should verify authorization status before every visit and initiate renewal requests well before the current authorization expires.
Compliance and Audit Preparation
The OIG and CMS regularly audit therapy billing, with 97110 receiving particular attention due to its high utilization. Audits typically review whether the documented time supports the units billed, whether the service was skilled (requiring the expertise of a trained therapist), whether the plan of care was current and signed by a physician, and whether progress was documented toward measurable functional goals.
Practices should conduct monthly internal audits of therapy documentation, reviewing a sample of claims from each treating therapist. Key metrics include average units per visit, time documentation accuracy, goal specificity, and progress note quality. Identifying and correcting documentation deficiencies before an external audit protects the practice from recoupment demands.