A patient can spend 30 minutes strengthening the hip, improving shoulder range of motion, or working through a graded exercise program and still leave the billing team with more questions than answers. Was all of that time truly skilled therapeutic exercise? How many units does Medicare allow? Does another timed service change the unit calculation? And if a PTA helped with treatment, does the CQ modifier belong on the claim?
Those questions sit at the center of CPT code 97110. The code is widely used in physical and occupational therapy, but it is also easy to over-simplify. It is not simply an “exercise code.” It is a timed therapeutic procedure that must be connected to a documented impairment, a treatment goal, and skilled intervention.
Medicare adds another layer because its timed-code billing method looks at the total timed treatment minutes for the discipline on that date of service, not just each code in isolation. The familiar “8-minute rule” is useful shorthand, but it can become misleading when several timed codes are performed in the same session.
For 2026, the code itself is not new. The more important changes are around Medicare therapy operations: the KX modifier threshold is $2,480 for PT and SLP combined and separately $2,480 for OT, and CMS has an active Recovery Audit Contractor review topic examining medical necessity, documentation, and KX use on therapy claims that includes 97110. The practical lesson is straightforward: unit math matters, but so does the record behind the units.
CPT 97110 at a Glance
| Question | Practical answer |
| What does 97110 represent? | A timed therapeutic procedure using exercise to improve strength, endurance, range of motion, or flexibility. |
| Is it timed? | Yes. It is reported in 15-minute units. |
| Does Medicare use the 8-minute rule? | Yes, as part of its timed-code methodology. Total timed treatment minutes determine the total number of billable units. |
| Can 97110 be billed more than once in a session? | Yes, when the documented treatment time supports multiple units. |
| Is 97110 the same as 97112? | No. 97112 is neuromuscular re-education and addresses different treatment goals. |
| Is 97110 the same as 97530? | No. 97530 focuses on dynamic therapeutic activities directed toward functional performance. |
| Which therapy modifiers may apply? | GP for PT plans, GO for OT plans, and CQ/CO when assistant involvement meets Medicare rules. |
| What is the 2026 KX threshold? | $2,480 for PT and SLP combined; $2,480 separately for OT. |
What Is CPT Code 97110?
CPT 97110 is used for a therapeutic procedure involving exercise, reported in 15-minute increments. CMS describes the service as exercise intended to develop or improve areas such as strength, endurance, range of motion, and flexibility.
That sounds broad, and it is. A therapist might use 97110 for resisted strengthening, active or assisted range-of-motion work, stretching, progressive loading, endurance exercises, or a carefully advanced home-exercise program. The exact exercise is less important than the reason it is being performed and the skill required to deliver it.
For Medicare billing, the record should show more than a list of repetitions. The exercise needs to make sense in the context of the patient’s documented impairment and functional goals. If the patient is working on quadriceps strength after knee surgery, for example, the note should connect the exercise to weakness, mobility, gait, transfers, stair use, or another relevant functional limitation.
CMS’s current outpatient therapy guidance emphasizes that timed therapy services require direct one-on-one treatment time. Minutes spent waiting, resting, or exercising independently while the therapist is not providing skilled treatment are not counted as timed treatment minutes. The current CMS article on Outpatient Physical and Occupational Therapy Services gives detailed examples of how those minutes should be counted.
What Counts as Therapeutic Exercise?
There is no single exercise list that automatically maps to 97110. The same movement can be appropriate under one code in one encounter and inappropriate in another if the therapeutic purpose is different.
Common 97110 interventions may include:
- Progressive resistive exercise for documented weakness
- Active, active-assisted, or resisted range-of-motion exercise
- Stretching intended to improve measurable flexibility or mobility restrictions
- Endurance training tied to a functional limitation
- Exercise progression following orthopedic surgery or injury
- Therapeutic exercise for postural or movement impairments when the primary objective is strength, endurance, ROM, or flexibility
- Instruction and progression of a home exercise program when skilled therapy is needed to teach, modify, or advance the exercises
What matters is the treatment objective. If the main goal is balance, coordination, proprioception, or motor control, 97112 may fit better. If the patient is practicing a functional task such as repeated lifting, reaching, carrying, or simulated work activity, 97530 may be more appropriate. Coding should follow the service actually furnished rather than the reimbursement amount attached to a code.
Is CPT 97110 a Timed Code?
Yes. CPT 97110 is a 15-minute timed code.
That does not mean Medicare requires exactly 15 minutes before the first unit can ever be billed. Medicare uses a timed-code methodology that allows one unit when the total timed treatment for the discipline reaches at least 8 minutes, assuming the other billing requirements are met.
The important word is total. If several timed procedures are furnished on the same day, Medicare does not simply run a separate 8-minute calculation for each code and add the results together. The total timed-code treatment minutes first determine how many units are available for the session. Those units are then allocated among the individual timed services.
This distinction is one of the most common sources of therapy billing errors.
How Medicare’s 8-Minute Rule Works for 97110
CMS therapy guidance uses the following ranges for 15-minute timed services:
| Total timed treatment minutes | Maximum timed units |
| 0-7 minutes | 0 units |
| 8-22 minutes | 1 unit |
| 23-37 minutes | 2 units |
| 38-52 minutes | 3 units |
| 53-67 minutes | 4 units |
| 68-82 minutes | 5 units |
| 83-97 minutes | 6 units |
| 98-112 minutes | 7 units |
| 113-127 minutes | 8 units |
The CMS Billing and Coding article for outpatient PT and OT explains this methodology and provides unit-allocation examples.
One Unit of 97110
If a therapist provides 10 minutes of 97110 and no other timed service, Medicare’s methodology supports one timed unit because the treatment falls in the 8-22 minute range.
If only 7 minutes of therapeutic exercise are provided, 97110 is not separately billable under the Medicare timed-code rule because the minimum threshold has not been reached.
Two Units of 97110
If 97110 is the only timed service and the therapist provides 25 minutes, the session supports two units because 25 minutes falls within the 23-37 minute range.
The same would be true for 30 minutes or 36 minutes, assuming the documented time represents skilled, direct treatment.
Three or More Units
A session containing 40 minutes of therapeutic exercise supports three units under Medicare because 40 minutes is within the 38-52 minute range.
At 55 minutes, four units may be supported because the total timed treatment falls within the 53-67 minute range.
These examples are simple because only one timed code is involved. The calculation becomes more interesting when 97110 is mixed with 97112, 97140, 97530, or another timed service.
How to Calculate Units When Several Timed Codes Are Performed
A therapist may perform more than one skilled intervention in the same visit. Medicare first looks at the combined timed treatment minutes, determines the total number of timed units available, and then allocates those units to the services performed.
Consider this example:
- 25 minutes of 97110 therapeutic exercise
- 8 minutes of 97530 therapeutic activities
- Total timed treatment = 33 minutes
Thirty-three minutes supports two timed units. The 25 minutes of 97110 contains one complete 15-minute block, leaving 10 minutes. The 8 minutes of 97530 contains no full block. After the first unit is assigned to 97110, the remaining minutes are compared. Because 97110 has the larger remainder, the second unit is also allocated to 97110.
The result is 2 units of 97110, while the 97530 treatment is still documented in the medical record. This exact style of example appears in current CMS therapy billing guidance.
Another CMS example uses:
- 18 minutes 97110
- 13 minutes 97140
- 10 minutes 97116
- 8 minutes 97035
- Total timed treatment = 49 minutes
Forty-nine minutes supports three units. One full 15-minute block goes to 97110. The remaining units are allocated to the services with the largest remaining minutes, resulting in one unit each of 97110, 97140, and 97116. The ultrasound time remains documented but does not create a fourth billable unit.
This is why a practice should not build a simplistic rule such as “8 minutes of every code equals one unit.” That can overstate the total units on the claim.
CPT 97110 vs. 97112
The distinction between 97110 and 97112 is a frequent coding question because both can involve active patient movement.
| Code | Primary treatment focus | Typical documentation emphasis |
| 97110 | Strength, endurance, ROM, flexibility | Resistance, repetitions, ROM, loading, progression, tolerance |
| 97112 | Neuromuscular re-education | Balance, coordination, proprioception, posture, motor control, movement retraining |
A patient performing standing exercises is not automatically receiving 97112. If the intervention is primarily resisted strengthening, 97110 may be the better fit. If the therapist is retraining balance reactions, proprioception, postural control, or movement sequencing, 97112 may be more appropriate.
The note should make the difference visible. Simply listing an exercise name without describing the therapeutic purpose can leave the claim difficult to defend during review.
CPT 97110 vs. 97530
CPT 97530 describes therapeutic activities using dynamic activities to improve functional performance. That is different from therapeutic exercise even though both services can involve movement.
A common example is lifting practice. If the patient performs a resisted exercise to strengthen the shoulder, 97110 may fit. If the patient practices lifting a box from the floor to a shelf to improve an actual work or household task, 97530 may be more appropriate.
The same principle applies to reaching, carrying, transfers, pushing, pulling, or task-specific movement. The billing code should reflect the purpose and structure of the intervention, not merely the fact that the patient moved.
Practices should also be cautious about automatically replacing 97110 with 97530 because a payer reimburses 97530 differently. Documentation must support the service that was actually performed.
CPT 97110 vs. 97140
CPT 97140 is manual therapy. It describes skilled manual techniques rather than active therapeutic exercise.
A session may legitimately contain both codes. For example, a therapist may perform joint or soft-tissue manual therapy and then progress the patient through strengthening or ROM exercises. The note should document the separate interventions and the time spent on each.
Under Medicare, the two timed services still feed into the same total timed-code calculation for the discipline. That means the unit total depends on the combined minutes, not on independently rounding each service.
CPT 97110 vs. Group Therapy 97150
CPT 97150 is used for group therapeutic procedures. It is not a substitute for individual 97110 simply because several patients happen to be exercising in the therapy gym at the same time.
CMS distinguishes direct one-on-one timed therapy from group treatment. A therapist cannot count the same 15-minute block as direct one-on-one 97110 for multiple patients at once. If a patient is exercising independently while the therapist is treating someone else, that independent time is not 97110 time for Medicare purposes.
This distinction matters in busy outpatient settings where several patients may be present simultaneously. Scheduling overlap does not change the time requirement attached to the billed service.
Documentation Requirements for CPT 97110
A defensible 97110 note should let another reviewer understand what was done, why it was done, how long it was done, and why skilled therapy was needed.
Useful documentation may include:
- The specific exercise or exercise category
- Resistance, load, repetitions, sets, range, duration, or other relevant treatment parameters
- The impairment being addressed
- The functional goal connected to the intervention
- Assistance, cueing, guarding, or modification supplied by the therapist
- Progression or regression made during the session
- Patient response and tolerance
- Exact timed treatment minutes
- Changes in symptoms or performance that affected treatment
A note that says only “ther ex performed” gives a reviewer very little to work with. A more useful entry might explain that resisted hip abduction was progressed because weakness continued to limit single-leg stability during stair use, and that the therapist adjusted resistance and technique in response to compensatory trunk motion.
CMS emphasizes exact treatment time for timed services. Waiting time, rest breaks when treatment is not occurring, documentation performed away from the active service, and unsupervised independent exercise are not added to the timed-code minutes.
Functional Goals and Medical Necessity
A diagnosis alone does not establish that every exercise session is medically necessary.
The record should connect treatment to a measurable impairment or functional limitation. Depending on the patient, that may involve walking, transfers, dressing, overhead reach, work activity, stair negotiation, joint mobility, endurance, or another meaningful function.
The skilled nature of the service also matters. Medicare coverage is not based on whether the exercise could theoretically be performed by anyone. The question is whether the patient’s condition requires the judgment, instruction, progression, monitoring, or modification of a qualified professional or permitted auxiliary personnel under the therapy rules.
Once the patient can safely and independently perform an unchanged exercise program without skilled input, continuing to bill the same service indefinitely becomes harder to support.
What Diagnosis Codes Can Support 97110?
There is no single ICD-10-CM diagnosis that automatically authorizes CPT 97110.
Therapeutic exercise may be used for many conditions, including orthopedic injuries, postoperative rehabilitation, weakness, reduced mobility, joint stiffness, neurologic conditions, and other impairments. The diagnosis reported should reflect the patient’s actual condition and the reason for treatment.
The more important documentation question is whether the diagnosis, impairments, goals, and intervention tell the same clinical story.
A payer may also have local coverage, authorization, benefit, or diagnosis requirements. Practices should verify the patient’s specific plan rather than assume that a diagnosis accepted by Medicare will necessarily satisfy a commercial insurer.
Modifier GP and GO With 97110
CMS identifies 97110 as an always-therapy service. Therapy claims therefore use the applicable discipline-specific modifier.
| Modifier | General Medicare use |
| GP | Service furnished under a physical therapy plan of care |
| GO | Service furnished under an occupational therapy plan of care |
| GN | Service under a speech-language pathology plan of care; 97110 is generally not an SLP service |
For a physical therapy plan of care, 97110 is commonly reported with GP. For an occupational therapy plan, GO is used.
CMS’s 2026 Annual Therapy Update provides the current therapy-code files and annual changes.
CQ and CO Modifiers for Therapy Assistants
The CQ and CO modifiers identify therapy services furnished in whole or in part by assistants under Medicare’s de minimis policy.
- CQ applies to outpatient physical therapy services furnished in whole or in part by a PTA when the Medicare rules require the modifier.
- CO applies to outpatient occupational therapy services furnished in whole or in part by an OTA when the rules require it.
These modifiers are used in addition to the applicable GP or GO modifier.
Assistant involvement does not mean every claim line automatically receives CQ or CO. Medicare applies a specific de minimis methodology and has exceptions for some unit-allocation situations.
For example, CMS provides a scenario in which a PTA furnishes 10 minutes of 97110 and the PT furnishes 5 minutes. The 15-minute total supports one unit, and the unit is billed with CQ because the PTA provided the majority of the service and the de minimis standard applies.
CMS also gives an example in which the PTA furnishes 5 minutes and the PT furnishes 30 minutes of 97110. Two units are supported by the 35 total minutes. Because the PT furnished two complete 15-minute units independently, the two units are billed without CQ; the PTA’s 5 minutes remain documented but do not change the modifier outcome.
The complete CMS examples are available on the CQ/CO billing examples page.
KX Modifier and the 2026 Medicare Therapy Threshold
For calendar year 2026, CMS set the KX modifier threshold at $2,480 for:
- Physical therapy and speech-language pathology services combined
- Occupational therapy services separately
The KX modifier is not permission to bill unlimited therapy. By using KX, the provider is attesting that services at and above the threshold remain reasonable and medically necessary and that the medical record supports continued treatment.
CMS states that claims above the applicable threshold that do not include KX are denied.
The current threshold is published on the CMS Therapy Services page and in the 2026 annual threshold transmittal.
Is the $2,480 Threshold a Therapy Cap?
No. Medicare’s old outpatient therapy caps were repealed.
The $2,480 amount is a KX modifier threshold, not a hard benefit cutoff. Therapy may continue beyond the threshold when it remains medically necessary and the documentation supports continued skilled care.
Medicare also retains a $3,000 targeted medical-review threshold for PT/SLP combined and separately for OT through 2027. Crossing that amount does not mean every claim is automatically reviewed. CMS describes the process as targeted medical review rather than universal review of all claims above the threshold.
The distinction matters. A clinic that treats the $2,480 amount as a hard annual limit may stop medically necessary care incorrectly. A clinic that ignores the threshold may instead create avoidable denials by omitting KX.
2026 Medicare Medical-Review Considerations
In April 2026, CMS approved a nationwide RAC issue titled Therapy Claims Billed with KX Modifier, Medical Necessity, and Documentation Requirements. The affected PT and OT code lists include 97110.
The review is complex rather than automated. According to CMS, reviewers may assess whether the therapy meets Medicare coverage criteria, follows applicable coding rules, is medically reasonable and necessary, and appropriately uses the KX modifier.
That does not mean 97110 is suddenly noncovered or unusually risky. It does mean that therapy organizations using KX in 2026 should expect the documentation to tell a coherent story: why skilled care is still needed, what measurable progress or clinical need exists, and why the treatment continues beyond the threshold.
The CMS RAC topic is available on the Therapy Claims Billed with KX Modifier review page.
Practical CPT 97110 Billing Examples
Example 1: Ten Minutes of Therapeutic Exercise Only
A PT provides 10 minutes of skilled shoulder ROM and strengthening. No other timed service is furnished.
Under Medicare’s timed-code methodology, 10 minutes falls in the 8-22 minute range, so 1 unit of 97110 may be reportable if the service is otherwise covered and documented.
Example 2: Seven Minutes of Therapeutic Exercise
A PT provides 7 minutes of 97110 and no other timed treatment.
Seven minutes does not reach Medicare’s minimum threshold. No timed unit is reported for 97110.
Example 3: Twenty-Five Minutes of 97110
A therapist provides 25 minutes of therapeutic exercise and no other timed service.
Twenty-five minutes supports 2 units of 97110 because the total timed treatment falls in the 23-37 minute range.
Example 4: 97110 Plus 97530
The session contains:
- 25 minutes 97110
- 8 minutes 97530
Total timed treatment is 33 minutes, supporting two units. Under CMS’s unit-allocation method, both units are allocated to 97110 because it has the complete 15-minute block and the larger remaining time.
The 97530 intervention still belongs in the treatment note even though it does not receive a separate unit in this example.
A PTA provides 10 minutes of therapeutic exercise and a PT provides 5 minutes of the same service.
The 15-minute total supports one 97110 unit. Under CMS’s assistant policy, that unit carries CQ because the PTA provided 10 minutes and the PT provided fewer than 8 minutes.
Example 6: Home Exercise Program Instruction
A patient is learning a new strengthening program after surgery. The therapist spends 12 minutes teaching technique, correcting compensation, changing resistance, and confirming that the patient can perform the program safely.
If the service is skilled and documented, the 12 minutes may support one unit of 97110 under Medicare’s timed methodology. Simply handing the patient a printed exercise sheet would not create the same billing support.
Common Unit-Calculation Errors
Treating Every 8 Minutes as a Separate Unit
Eight minutes can support the first timed unit under Medicare, but it does not mean each individual code with 8 minutes automatically earns its own unit. Total timed treatment minutes cap the total units for the discipline on that date.
Counting Untimed Services in the Timed-Code Total
Evaluation and other untimed-service minutes are not added to the timed-code minutes when calculating timed units.
Counting Rest or Independent Exercise
A patient may spend an hour in the clinic without receiving an hour of timed treatment. Only qualifying skilled treatment time is used in the timed-code calculation.
Rounding Every Code Independently
Independent rounding can overbill a session. Medicare expects practices to total timed treatment first and then allocate units.
Common Documentation and Coding Errors
Listing Exercises Without a Clinical Purpose
“Ther ex x 20 minutes” may show that something happened, but it says very little about why the service required skilled care.
Using 97110 for Every Active Intervention
Balance, motor control, functional task practice, gait training, and self-care training can belong to other code families. Code selection should follow the service objective.
Reusing an Unchanged Exercise Program Indefinitely
If the same program is repeated without progression, reassessment, modification, or other skilled input, the medical necessity for continued skilled treatment may become difficult to demonstrate.
Missing GP or GO
Because 97110 is an always-therapy service under Medicare, the applicable therapy modifier belongs on the claim.
Missing CQ or CO When Required
Assistant involvement should be evaluated under Medicare’s de minimis rules rather than ignored or automatically modifiered.
Adding KX Too Early or Too Late
KX is tied to the beneficiary’s accumulated therapy spending under the applicable threshold. Practices should monitor the threshold and apply KX when required, not as a routine modifier on every therapy claim.
Common Reasons 97110 Claims Are Denied
A denial can have more than one cause. Common problems include:
- Timed units that do not match documented minutes
- Missing GP or GO modifiers
- Missing KX after the threshold is reached
- Unsupported CQ or CO reporting
- Medical-necessity concerns
- Documentation that does not show skilled intervention
- Diagnosis or authorization mismatch
- Services outside the approved visit or unit count
- Duplicate or overlapping timed services
- Therapy provided outside applicable plan-of-care requirements
When a claim is denied, start with the remittance message and the submitted claim rather than assuming the code itself is wrong. MedIntelHub’s Claim Denials: Prevention and Follow-Up Checklist provides a broader workflow for deciding whether a claim needs correction, documentation, reconsideration, or appeal.
For organizations reviewing the full claim lifecycle, see Medical Billing Workflow: From Patient Visit to Payment.
Medicare Part B does not treat prior authorization for ordinary outpatient 97110 exactly the way many commercial plans do. Commercial insurers, Medicare Advantage plans, workers’ compensation programs, and other payers may require authorization, limit visits, approve a specific number of units, or require periodic reauthorization.
An approved authorization also does not guarantee payment if the claim does not match the approved provider, dates, code, location, or units.
MedIntelHub’s Prior Authorization guide explains the operational checks practices can use before and after treatment.
CPT 97110 Pre-Bill Checklist
Before releasing a 97110 claim, confirm:
- The intervention actually represents therapeutic exercise directed at strength, endurance, ROM, or flexibility.
- The service required skilled treatment rather than unsupervised independent exercise.
- Exact timed treatment minutes are documented.
- Rest, waiting, and independent exercise time have not been added to the billable minutes.
- Total timed minutes for the discipline support the total units billed that day.
- Units were allocated correctly when several timed codes were used.
- The diagnosis and treatment goals support the service.
- The note documents what was performed and how the patient responded.
- GP or GO is present when required by Medicare.
- CQ or CO has been evaluated when a PTA or OTA participated.
- The beneficiary’s 2026 therapy spending has been checked for KX threshold purposes.
- KX is present when the applicable threshold has been reached and continued therapy is supported.
- Authorization or visit limits have been checked for non-Medicare payers when applicable.
- The claim does not contain overlapping one-on-one timed services that could not have been performed simultaneously.
Frequently Asked Questions About CPT 97110
What is CPT code 97110 used for?
It is used to report timed therapeutic exercise intended to improve areas such as strength, endurance, range of motion, or flexibility when the service is skilled and otherwise meets payer requirements.
How long is one unit of 97110?
The code is defined in 15-minute increments. Under Medicare’s timed-code methodology, the first unit may be supported beginning at 8 minutes, while total timed treatment minutes determine the total number of units for the day.
Can I bill one unit of 97110 for 8 minutes?
Under Medicare Part B timed-code rules, yes, if the total timed treatment is at least 8 minutes and the service is otherwise billable. Other payers may use different methodologies.
How many units can be billed for 30 minutes of 97110?
If 97110 is the only timed service, 30 minutes generally supports 2 units under Medicare because it falls within the 23-37 minute range.
How many units can be billed for 45 minutes of 97110?
Forty-five timed minutes generally support 3 units under Medicare because they fall within the 38-52 minute range.
Can 97110 and 97112 be billed on the same day?
They may both be reported when distinct, medically necessary interventions were actually performed and documented. The total timed minutes still control the total number of timed units allowed under Medicare.
Can 97110 and 97530 be billed together?
Potentially. The record should distinguish therapeutic exercise from dynamic functional activities and support the time attributed to each service.
Does 97110 require modifier GP?
When the service is furnished under a Medicare physical therapy plan of care, GP is generally required. Under an occupational therapy plan, GO is used instead.
When is CQ used with 97110?
CQ is used when PTA involvement meets Medicare’s assistant-modifier rules. It is not applied merely because a PTA was somewhere in the clinic; the actual minutes and de minimis policy determine whether it belongs on the line.
What is the Medicare KX threshold for 2026?
The 2026 threshold is $2,480 for PT and SLP services combined and $2,480 separately for OT services.
Is $2,480 the maximum Medicare will pay for therapy in 2026?
No. It is a KX modifier threshold, not a hard therapy cap. Medically necessary services may continue when documentation supports them and the applicable billing requirements are met.
What is the $3,000 therapy threshold?
It is the targeted medical-review threshold retained by Medicare. Not every claim above that amount is automatically reviewed.
Does 97110 require direct one-on-one time?
CMS therapy guidance treats 97110 as a therapeutic procedure requiring direct one-on-one patient contact for timed billing. Independent exercise time is not counted as 97110 treatment time.
Can a home exercise program be billed as 97110?
Teaching, modifying, or progressing a home exercise program may support 97110 when the work is skilled, timed, and documented. Simply giving a patient routine written exercises without skilled intervention is different.
Do all insurers follow Medicare’s 8-minute rule?
No. Commercial and other payers may use different timed-code methodologies, authorization rules, or unit policies. The payer’s current policy should be checked before assuming Medicare’s method applies.
What Matters Most When Billing 97110
CPT 97110 is easy to recognize on a therapy claim, but correct reporting depends on more than seeing the word “exercise” in the note.
The intervention needs to be therapeutic exercise, the time has to reflect actual skilled one-on-one treatment, and the documented impairment and functional goals should explain why the exercise belongs in skilled therapy. Under Medicare, the day’s total timed minutes then determine how many timed units are available.
The 2026 Medicare changes are mostly operational rather than a rewrite of 97110 itself. The KX threshold is now $2,480, the $3,000 targeted medical-review threshold remains in place, and CMS has an active RAC review topic that includes 97110 claims billed with KX. Those changes make accurate time, modifier use, and continued-need documentation especially important.
A good billing workflow therefore starts with the encounter, not the code. Document what the patient needed, what skilled intervention occurred, how long it lasted, how the patient responded, and how the service moved the plan of care forward. The unit calculation should then follow that record.
Resources
Centers for Medicare & Medicaid Services – Therapy Services
CMS maintains current Medicare outpatient therapy information, including the 2026 KX thresholds, assistant-modifier policy, and annual therapy updates.
Centers for Medicare & Medicaid Services – Outpatient Physical and Occupational Therapy Billing and Coding
This Medicare Coverage Database article explains timed-code calculations, treatment-time documentation, unit allocation, direct one-on-one therapy requirements, and examples involving 97110.
CMS: Outpatient PT and OT Billing and Coding
Centers for Medicare & Medicaid Services – CQ/CO Billing Examples
CMS provides detailed examples showing how PT/PTA and OT/OTA time affects CQ and CO reporting for timed services, including several 97110 scenarios.
Centers for Medicare & Medicaid Services – 2026 KX Modifier Threshold Update
CMS confirms the 2026 therapy threshold of $2,480 for PT/SLP combined and $2,480 for OT.
CMS: 2026 Therapy Threshold Update
Centers for Medicare & Medicaid Services – RAC Review Topic 0228
This 2026 review topic explains that documentation, medical necessity, coding, and KX use may be reviewed for affected outpatient therapy claims, including 97110.
CMS: Therapy Claims Billed with KX Modifier RAC Topic
MedIntelHub – New CPT Code Changes for 2026
For a broader look at annual coding changes, therapy-related updates, and the difference between CPT revisions and payer payment rules, see MedIntelHub’s current coding overview.
MedIntelHub: New CPT Code Changes for 2026
Editorial Guidelines & Medical Disclaimer
This article is intended for general educational and informational purposes. It does not establish medical necessity for an individual patient, determine coverage, or replace the current CPT code set, Medicare manuals, Medicare Administrative Contractor instructions, payer contracts, authorization requirements, or professional coding advice.
CPT is a registered trademark of the American Medical Association. CPT coding and descriptors can change, and the official current CPT resource should be used when submitting claims.
Therapy coverage and billing requirements can vary by payer, setting, provider type, plan of care, and date of service. Medicare’s timed-code methodology, GP/GO rules, CQ/CO policy, KX thresholds, and medical-review processes should not automatically be applied to commercial insurers unless that payer has adopted the same rules.
Clinical treatment decisions belong to the treating healthcare professional and should reflect the individual patient’s condition, goals, risks, and response to care. Nothing in this article directs patient-specific treatment or replaces clinical judgment.
MedIntelHub develops medical and billing content from authoritative sources and reviews it for accuracy and clarity. For information about sourcing, corrections, and editorial standards, review the MedIntelHub Editorial Policy.
David Bennett
David Bennett is an author at MedIntelHub, where he creates clear, practical, and well-researched content about healthcare, medical billing, insurance, and patient education. His goal is to make complex healthcare topics easier for readers to understand and use in everyday situations. David emphasizes accuracy, transparency, and reliable sourcing, using information from trusted organizations and official healthcare resources whenever possible. Content published by David is intended for educational purposes and should not replace advice from qualified medical, legal, or healthcare professionals.