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97110 CPT Code: The Essential Guide to Billing Therapeutic Exercises [2025 Update]

Stanley Efrem

Mar 13, 2025

CPT code 97110 stands as one of the most frequently billed therapeutic exercise procedures that insurance auditors examine closely. Healthcare providers bill millions of claims with this code each year, but even small documentation errors can trigger denied reimbursements and compliance problems.

Your therapeutic exercise CPT code billing must include exact documentation, precise time tracking, and a clear grasp of what payers require. The most important updates to CPT code 97110 guidelines will take effect in 2025. Your practice's financial health depends on staying up to date with proper billing practices.

This piece gives you a detailed walkthrough of billing therapeutic exercises correctly. You'll discover the newest reimbursement changes, documentation needs, and proven strategies that encourage engagement to maximize legitimate claims while you retain control of compliance.

2025 Updates to CPT Code 97110 Billing Guidelines

Medicare's 2025 fee schedule brings the most important adjustments to therapeutic exercise billing practices. The conversion factor has decreased to USD 32.35, down from USD 33.29 in 2024 [1]. On top of that, it sets the reimbursement rate for CPT code 97110 therapeutic exercises at USD 28.79 for 2025 [2].

Recent changes in reimbursement policies

The new therapy thresholds mark a notable update. The 2025 combined physical therapy and speech-language pathology services threshold stands at USD 2,410, among other separate USD 2,410 threshold for occupational therapy services [1]. The targeted medical review process keeps its USD 3,000 threshold for both PT/SLP combined services and OT services independently [3].

The Centers for Medicare & Medicaid Services (CMS) now applies a Multiple Procedure Payment Reduction (MPPR) rate of 50% for subsequent therapy services patients receive on the same day [3]. This policy ensures the service with the highest practice expense relative value unit gets full payment, while additional services receive half the rate.

Updated documentation standards

Documentation requirements have seen big changes. The physician signature process for therapy plans of care marks a key update. Starting January 2025, therapists can use a signed and dated physician order or referral to meet the physician signature requirement on the plan of care. They must document POC submission to the physician within 30 days after completing the original evaluation [2].

CMS now wants better documentation for services that exceed the therapy threshold. Providers must add the KX modifier and keep complete documentation that proves medical necessity when billing beyond USD 2,410 [3]. Claims above this threshold without the required KX modifier face automatic denial.

How these changes affect your practice

Your practice will see operational and financial impacts from these updates. The lower conversion factor means you'll need careful financial planning to stay profitable. Practices that often provide multiple therapy services in single sessions will feel the MPPR policy's effects more strongly.

The new physician signature process makes administrative tasks easier and could speed up documentation. You still need to track POC submissions carefully and keep complete records of physician communications.

Practices that often exceed therapy thresholds will need reliable documentation systems. Electronic health record templates designed specifically for therapeutic exercise documentation help ensure you meet these new requirements.

The USD 3,000 targeted medical review threshold stays the same through 2028 [3]. Not every claim above this amount faces review, but you should keep detailed documentation that proves medical necessity, especially for patients who use many services.

CMS has made supervision requirements more flexible by moving to general supervision guidelines for physical therapist assistants and occupational therapy assistants who provide outpatient services [1]. This change helps therapy practices create more efficient staffing schedules.

Maximizing Legitimate Reimbursement for Therapeutic Exercises

Billing practices for therapeutic exercises just need careful attention and smart planning. You must understand fee structures, payer requirements, and ways to prevent denials. These are the foundations of a healthy revenue cycle.

Setting appropriate fees

The best fees for CPT code 97110 should balance market rates with practice costs. Medicare's 2024 fee schedule shows a reimbursement rate decrease to USD 28.82 [4]. Private practices must assess their fee structures based on:

Practice overhead costs
Local market competition
Geographic location
Payer mix ratios

Payer-specific considerations

Each insurance carrier has its own requirements for therapeutic exercise claims. Here's what you should check before submitting claims:

The first step is to confirm patient eligibility and benefits coverage before providing service [5]. Make sure you comply with payer-specific documentation standards and justify medical necessity [6]. You should also know each payer's policies about the eight-minute rule for timed codes [6].

Medicare needs the KX modifier for claims that go over the therapy threshold. You must provide detailed documentation that supports medical necessity [7]. Services in facilities get different reimbursement rates than those in professional offices [7].

Strategies to reduce claim denials

A resilient denial prevention system starts with accurate documentation. Recent analyzes show claim denials have gone up substantially through 2023 [8]. Here's how to minimize denials:

Documentation Excellence

Record specific exercises performed
Track exact time spent on direct patient care
Document patient progress over multiple sessions [6]

Coding Accuracy

Verify correct modifier usage
Ensure proper code combinations
Submit claims within required timeframes [5]

Process Optimization

Implement automated verification systems
Conduct regular internal audits
Provide ongoing staff training [9]

Payers look closely at documentation before they approve reimbursement for therapeutic exercise claims [6]. Keep complete records of exercise parameters, including sets, repetitions, and resistance levels. Document progressive overload principles to show that treatment works [6].

Insurance verification helps prevent denials. Studies show that 90-93% of rejections happen because of preventable data entry mistakes [5]. Set up protocols to verify patient information before providing service.

Keep track of denial patterns to spot recurring issues. Monitor key metrics like initial submission denial rates, appeal timeframes, and reworked claim outcomes [8]. Use this information to make your billing process better and improve staff training programs.

These strategies and proper documentation protocols can help practices improve their clean claim rates substantially. Note that good documentation supports reimbursement and proves that therapeutic exercise interventions are medically necessary [10].

Creating Audit-Proof Documentation for 97110

Good documentation protects you against audits of therapeutic exercise claims. Insurance companies look at every detail of your records. You need complete documentation that shows why treatment was needed and how well it worked.

Medical necessity justification

Your records must show how therapeutic exercises help patient outcomes. Each session needs:

Details about the specific problem area
How exercises relate to functional limitations
Exercise adjustments based on how patients respond

Physical therapists must show that their prescribed exercises help patients recover [6]. Since therapeutic exercises are key to many treatment plans, insurance companies carefully check documentation before paying claims [6].

Objective measurements and progress tracking

The best documentation captures measurable outcomes during treatment. Objective measures give solid proof of improvement beyond what patients say [11]. You must track these key elements:

Exercise Parameters

Sets and reps completed
Resistance or weight used
How long exercises were held
Changes in muscle tightness or end feel [12]

Progress tracking means documenting better functional abilities over time. This connects to progressive overload - patients do more exercise or work harder with each visit [6]. Insurance companies might question continued therapy if you can't show progress across multiple sessions [6].

Red flags that trigger audits

Knowing what triggers audits helps protect your practice. The biggest red flags are:

Documentation Issues

Missing progress notes or treatment goals
No objective findings to support medical necessity
Copied notes that don't reflect patient changes

Cookie-cutter treatments raise immediate concerns. Insurance companies will ask questions if your treatment stays the same from start to finish, or if most patients get identical exercises despite different problems [14].

Long treatment periods without clear improvement catch attention quickly. Insurance companies want to see measurable progress through objective outcomes like better range of motion or improved function. Claims often get denied when documentation doesn't support why treatment was needed.

Your records stay audit-proof when each note shows techniques used, patient progress, and clear session goals [15]. Make sure to write down the specific exercises patients do and explain how these help achieve functional outcomes [12].

Common Billing Errors and How to Avoid Them

Billing errors with CPT code 97110 can trigger claim denials and delay your reimbursements. A full picture of these common mistakes and preventive measures will give your practice a smoother revenue cycle.

Incorrect time tracking

Time-based billing mistakes often come from misunderstanding the eight-minute rule. Physical therapists need to track one-on-one time with patients from their original assessment through documentation [16]. You can bill for time spent on these activities:

Documentation during patient sessions
Consultation with referring physicians during treatment
Direct patient assessments

Insufficient documentation

Documentation errors top the list of claim denial reasons [17]. Here's what you need for compliant records:

Required Elements

Specific exercises performed and their purpose
Exercise parameters (sets, repetitions, resistance)
Patient's response to treatment
Progress toward functional goals

Poorly documented services raise red flags in audits. Heavy reliance on therapeutic exercise code 97110 without proper justification can trigger extra scrutiny [16].

Improper code combinations

The National Correct Coding Initiative (NCCI) edits are vital for accurate billing. CMS created these edits to control improper coding that leads to inappropriate payments [18]. Here's what you should know:

Modifier Usage

Use modifier 59 only for truly separate services
X modifiers (XE, XS, XP, XU) work better than 59 in most cases
Your documentation must support modifier application

Some code combinations automatically trigger denials unless appropriate modifiers justify their use. To cite an instance, therapeutic exercise claims often get rejected because of incorrect modifier use.

Duplicate billing mistakes

Duplicate submissions create problems more often than you might expect [2]. They happen in several ways:

Common Scenarios

Multiple submissions for similar services
Billing same procedure codes without proper modifiers
Claims resubmitted before initial processing ends

You should wait 30 days after the initial claim submission before trying again [2]. Check your remittance advice for processed claims to understand why they were denied before resubmitting.

Your practice needs reliable verification systems to catch potential errors before submission. The core team should receive regular training on documentation standards. EHR templates designed specifically for therapeutic exercise documentation help reduce these common billing mistakes [19].

Note that fixed-rate payers need special attention. Despite their name, these payers typically cap their reimbursement rather than providing true fixed payments [16]. Document all unit numbers carefully, even with fixed-rate arrangements, to avoid underbilling.

Conclusion

Billing therapeutic exercises correctly just needs careful attention and a solid grasp of current guidelines. CPT code 97110 billing might look complex, but understanding the basics will protect your practice from denials and audits while ensuring proper reimbursement.

The most important changes in Medicare's 2025 updates affect reimbursement rates and documentation requirements. Your practice's revenue cycle stays protected by keeping up with these changes. Proper documentation becomes your best defense against audits, and precise time tracking with correct code combinations prevents billing errors that can get pricey.

Your success with therapeutic exercise billing relies on three essential elements. You need detailed documentation, a clear understanding of payer requirements, and quick verification systems. Your practice can deliver quality patient care without claim rejection worries once these foundational pieces are in place.

Your current billing processes should align with the latest guidelines through regular reviews. A proactive approach to therapeutic exercise billing strengthens your practice's financial health and reduces denials.

FAQs

What are the key updates to CPT code 97110 billing guidelines for 2025?

The 2025 updates include a decreased conversion factor to $32.35, a reduced reimbursement rate of $28.79 for CPT code 97110, new therapy thresholds of $2,410 for combined PT/SLP services and OT services, and changes to physician signature requirements for therapy plans of care.

How can healthcare providers maximize legitimate reimbursement for therapeutic exercises?

To maximize reimbursement, providers should set appropriate fees based on market rates and practice costs, understand payer-specific requirements, verify patient eligibility before service delivery, maintain detailed documentation, and implement strategies to reduce claim denials.

What elements are crucial for creating audit-proof documentation for CPT code 97110?

Audit-proof documentation should include clear medical necessity justification, specific exercise parameters, objective measurements of patient progress, and regular updates to treatment plans. It's important to avoid copy-pasting notes and to demonstrate measurable improvements over time.

What are common billing errors when using CPT code 97110 and how can they be avoided?

Common errors include incorrect time tracking, insufficient documentation, improper code combinations, and duplicate billing. These can be avoided by understanding the eight-minute rule, maintaining detailed records, properly using modifiers, and implementing robust verification systems.

How can practices implement efficient billing workflows for therapeutic exercises?

Efficient billing workflows can be achieved by using EHR templates specifically designed for therapeutic exercise documentation, streamlining the documentation process, providing ongoing staff training on proper billing practices, and regularly auditing internal processes to identify areas for improvement.