97110 cpt code is a time based therapeutic procedure code to report therapeutic exercises designed to strengthen endurance, range of motion and flexibility. It is widely utilized in physical and occupational therapy but proper reporting will require consideration of whether or not the treatment was delivered. The amount of time spent on the treatment, the medical necessity for the treatment, the appropriate plan of care and the specific rules of the payers regarding reporting rules and regulations.
This guide covers 97110 code details including the code description, code definition, CPT code use, units, PT documentation issues, code modifiers, reimbursement factors, related codes and common billing issues.
Quick Answer
Therapeutic exercise, each 15-minute unit in one or more areas (CPT 97110). The exercise should relate to the therapeutic objectives, e.g. strength, endurance, range of motion or flexibility. Treatment time is important for the units when determining 97110’s since it is a timed therapy procedure. There are also Medicare requirements for therapy modifiers, medical necessity, skilled care and some threshold related modifiers.
| Field | Information |
|---|---|
| CPT Code | 97110 |
| Code Type | Therapeutic procedure |
| Core Service | Therapeutic exercise |
| Time Basis | Each 15 minutes |
| Primary Purposes | Strength, endurance, range of motion, flexibility |
| Common Setting | Physical and occupational therapy |
| Patient Type | Not a new-patient or established-patient E/M code |
| MDM Requirement | Not applicable |
| Common Related Codes | 97112, 97116, 97140, 97530 |
| Medicare Therapy Modifiers | May include GP and, when applicable, CQ; other modifiers depend on the circumstances and payer. |
What Is the 97110 CPT Code?
The 97110 CPT code is for a therapeutic procedure using exercises to develop or improve strength, endurance, range of motion and flexibility. The code is presented in 15-minute chunks.
Therapeutic exercise is the service that is coded with CPT 97110, and is identified by the American Medical Association as a clinical service example as follows: Direct therapeutic exercises after rotator cuff repair.
From a practical standpoint, the treatment should be structured therapeutic exercise directed to a documented impairment or functional limitation, as opposed to a general exercise or physical activity without a therapeutic purpose and 97110 is generally applicable.
97110 CPT Code Definition in Simple Terms
One way to think about the code is:
97110 = therapeutic exercise + skilled intervention + therapeutic purpose + timed service
The exercise must be related to the patient’s illness and treatment goals. The medical record should document the rationale for the intervention and the need for skilled therapy.
What Does 97110 cpt code Include?
CPT 97110 is used for therapeutic exercises that are directed towards outcomes such as:
- Increasing muscle strength
- Improving muscular endurance
- Increasing or restoring range of motion
- Improving flexibility
- Treatment for functional limitations using therapeutic exercises
The specific exercises can vary considerably. The important issue is not simply the name of the exercise but why it was performed, how it was performed, and how it relates to the patient’s documented condition and goals.
For example, an exercise using a therapy ball may qualify as therapeutic exercise when it is being used to improve strength or another therapeutic objective. CMS guidance also emphasizes documenting changes to the exercise program and the skilled rationale for those changes.
When Should 97110 cpt code Be Used?
CPT 97110 should be considered when the documented service consists of therapeutic exercises that address an appropriate clinical impairment or functional limitation and the service meets the applicable payer’s requirements.
Examples may include:
- Progressive strengthening following an injury
- Therapeutic exercises to restore shoulder range of motion
- Exercises designed to improve lower-extremity strength
- Flexibility exercises incorporated into a documented rehabilitation program
- Therapeutic exercise progression based on the patient’s response to treatment
The code should not be selected merely because a patient performed an exercise during a therapy visit. The documentation should establish the therapeutic purpose and skilled nature of the service.
Example: 97110 cpt code May Be Appropriate
A patient suffering from shoulder injury has documented weakness and limited range of motion. The therapist gives and advances a particular strengthening and range of motion exercises during a therapy session that depend on the patient’s deficits and treatment goals.
Consider using 97110 if the service is for the appropriate coverage and coding, and the treatment is documented appropriately.
Example: Exercise Alone Does Not Automatically Establish 97110
A patient performs a general exercise routine independently without documented skilled intervention, therapeutic progression, or a connection to the treatment plan.
Simply documenting that the patient exercised does not automatically establish that 97110 is reportable. The complete record must support the service and applicable payer requirements.
How Is 97110 cpt code Billed in Units?
CPT 97110 is a 15-minute timed code.
For Medicare outpatient therapy, CMS uses total timed treatment minutes to determine the number of units that may be reported for timed services. The Medicare framework generally uses the following ranges:
| Total Timed Treatment Minutes | Maximum Timed Units |
|---|---|
| 8–22 | 1 |
| 23–37 | 2 |
| 38–52 | 3 |
| 53–67 | 4 |
| 68–82 | 5 |
| 83–97 | 6 |
| 98–112 | 7 |
| 113–127 | 8 |
For Medicare, fewer than 8 total timed treatment minutes generally does not support billing a timed unit. The total timed minutes for the day are considered when determining the number of timed units, and the units then have to be allocated appropriately among the timed services performed.
Important: These are Medicare billing rules. Other payers may use different policies, so billers should verify the applicable payer’s requirements.
How Are Multiple Timed Services Allocated?
Suppose a Medicare therapy session includes:
- 20 minutes of 97110
- 20 minutes of 97112
The total timed treatment time is 40 minutes, which supports three timed units under the Medicare framework.
Each service has one complete 15-minute block. The remaining minutes are then considered when assigning the additional unit. Because both services have five remaining minutes, either service may receive the additional unit under the CMS example.
The resulting claim could therefore be:
- 2 units of 97110 + 1 unit of 97112, or
- 1 unit of 97110 + 2 units of 97112
CMS provides this type of example in its outpatient therapy billing guidance.
Does 97110 cpt code Require 15 Minutes?
The code is defined on a 15-minute unit basis, but Medicare’s timed-code methodology does not mean that every individual service must always reach exactly 15 minutes before any unit can ever be reported.
Under Medicare’s therapy billing methodology, total timed treatment minutes for the day are considered, with units allocated based on the documented time for each service. CMS uses the 8-to-22-minute range for one total timed unit, followed by additional ranges for additional units.
It is important, as a common billing error is to assume that the code descriptor is always at 15 minutes per service.
What Documentation Supports 97110 cpt code?
Documentation should allow a reviewer to understand:
- What therapeutic exercises were performed
- How much time was spent
- Why the exercises were medically appropriate
- Which impairment or functional limitation was being addressed
- What skilled intervention the therapist provided
- How the intervention relates to the patient’s treatment goals
- How the patient responded to treatment
- What changes or progression were made when applicable
CMS guidance specifically discusses documentation of new exercises or modifications to an exercise program as part of demonstrating the skilled nature of therapy. It also discusses documenting objective findings, functional effects, exercises performed, their purpose, instructions, and assistance required.
A Strong 97110 Treatment Note Should Connect the Dots
A useful treatment note does more than state:
“Therapeutic exercises performed for 30 minutes.”
A stronger record explains the intervention and its clinical purpose.
For example, documentation might identify:
- Specific exercises performed
- Number of sets or repetitions when relevant
- Resistance or progression
- Range-of-motion work
- Assistance or cueing provided
- Patient tolerance and response
- Functional objective being addressed
- Changes made compared with the previous session
- Total treatment time
The exact documentation format depends on the provider, setting, payer, and applicable documentation requirements.
Why Is Medical Necessity Important for 97110 cpt code?
Correct code selection alone does not establish payment.
Medicare pays for outpatient therapy if it is reasonable and necessary and the therapy is covered by Medicare. The guidance from CMS to cover therapy focuses on the connection of the therapy to a plan of treatment and specific therapeutic goals, as well as the requirement of the skills of qualified therapy personnel when relevant.
A claim can then be coded correctly for the CPT code but be denied if the record does not demonstrate medical necessity, skilled care, appropriate treatment goals, or any other required coverage considerations.
What Modifiers May Apply to 97110 cpt code?
No modifier should be automatically added to all 97110 claims. Depending on the situation, the payer, the type of provider, the plan of care, and applicable coding rules, the modifiers used to select the code will vary.
GP Modifier
For Medicare therapy claims, GP Modifier identifies services furnished under a physical therapy plan of care when required by Medicare rules.
CMS identifies 97110 among the “always therapy” codes for which the appropriate therapy modifier is required. For physical therapy, the applicable modifier is GP.
GO Modifier
GO Modifier is associated with services furnished under an occupational therapy plan of care when applicable under Medicare requirements.
The appropriate therapy modifier therefore depends on the discipline and plan of care rather than simply on the CPT code itself.
CQ Modifier
The CQ modifier has a specific Medicare application when a physical therapist assistant furnishes services in whole or in part under the applicable PTA rules.
CMS provides current examples involving 97110 and the CQ modifier. For example, when a PTA provides a qualifying portion of a unit and the PT provides the remainder, CMS’s de minimis methodology may determine whether CQ is required.
The CQ modifier should not be added simply because a PTA participated in the patient’s care. The actual circumstances and Medicare rules must be evaluated.
KX Modifier
The KX modifier is different from GP and CQ.
Under Medicare, KX is associated with an attestation that services above the applicable therapy threshold are medically necessary and reasonable, with supporting justification documented in the medical record.
For CY 2026, CMS lists the KX threshold at:
- $2,480 for PT and SLP services combined
- $2,480 for OT services
CMS also sets a different $3,000 targeted medical review threshold for 2026.
These are Medicare thresholds, and should not be considered universal requirements for commercial insurance.
Should Modifier 59 Be Used With 97110 cpt code?
Modifier 59 should not be applied to avoid a denial or to ensure payment. According to CMS, when using modifiers with NCCI, modifiers 59, XE, XP, XS, and XU are only used when appropriate circumstances exist. Modifier 59 is usually used to indicate a separate procedure for services that meet the coding circumstances for separate coding.
Whether 97110 can be separately reported with another therapy service depends on the applicable code-pair edit, the circumstances of the services, and the payer’s rules.
The correct approach is:
Check the applicable NCCI edit first, then determine whether the documented clinical circumstances support a modifier.
Note that modifier 59 is not to be used simply because two services were provided in the same visit.
CPT 97110 vs. 97112 vs. 97140 vs. 97530
These therapy codes may be used simultaneously as part of the rehabilitation claim, but are different types of rehabilitative interventions.
| Code | General Purpose | Time Basis |
|---|---|---|
| 97110 | Therapeutic exercise for strength, endurance, ROM, and flexibility | Each 15 minutes |
| 97112 | Neuromuscular reeducation | Each 15 minutes |
| 97140 | Manual therapy techniques | Each 15 minutes |
| 97530 | Therapeutic activities using functional, dynamic activities | Each 15 minutes |
CMS lists these codes as distinct therapy services and provides examples of how their timed minutes are combined and allocated for Medicare billing.
97110 vs. 97112
The primary difference is the therapeutic goal and intervention.
97110 is used to focus therapeutic exercises on building strength, endurance, range of motion or flexibility.
97112 is aimed toward neuromuscular reeducation (areas of movement, balance, coordination, kinesthetic sense, posture, or proprioception).
The documentation should demonstrate the validity of the selected code in describing the service provided.
97110 vs. 97140
97110 represents therapeutic exercise.
97140 represents manual therapy techniques.
If both services are performed during the same session, the record should separately support the interventions, their time, and their medical necessity. Applicable NCCI edits and payer-specific requirements should also be reviewed.
97110 vs. 97530
97110 focuses on therapeutic exercise.
97530 focuses on therapeutic activities involving functional, dynamic activities.
It should be based on what the intervention is, and the therapeutic purpose rather than the patient’s diagnosis.
What Is 97110 cpt code Reimbursement?
There is no single nationwide reimbursement amount for 97110 cpt code.
Payment can vary based on factors such as:
- Payer
- Geographic location
- Place of service
- Provider circumstances
- Contractual fee schedules
- Medicare payment methodology
- Applicable adjustments
- Units reported
- Coverage and medical necessity
- Patient benefit structure
Medicare Physician Fee Schedule (MPFS) data is published by CMS and can be used for research to determine applicable information about Medicare payments. Don’t assume that an online reimbursement figure represents the actual amount of payment an individual may be entitled to.
So a website should not claim that “97110 pays $X” without specifying the locality, the payment method, the year and payment issuer.
Does 97110 cpt code Have an RVU?
Medicare Physician Fee Schedule data is the source for the representation of CPT 97110 and includes relative value information that is used to calculate Medicare payment rates.
However, an RVU is not the same thing as reimbursement.
Medicare payment methodology can involve components such as:
- Work RVU
- Practice expense
- Malpractice expense
- Geographic practice cost indices
- Conversion factor
- Other applicable payment rules
The current 2026 payment information is available in the current CMS Physician Fee Schedule data, and is not available from a previous article or a static reimbursement amount.
97110 cpt code RVU Values for 2026
CPT 97110 has a total RVU of 0.87 for 2026. CMS has separate RVUs for work, practice expense, and malpractice.
| RVU Component | 2026 Value |
|---|---|
| Work RVU | 0.45 |
| Practice Expense RVU | 0.41 |
| Malpractice RVU | 0.01 |
| Total RVU | 0.87 |
These values appear in CMS’s July 2026 Physician Fee Schedule release. The same practice expense RVU applies in both listed settings.
CMS calculates Medicare payments using RVUs and geographic adjustments. The conversion factor also affects the final Medicare payment amount. For the 2026 non-QP conversion factor, CMS lists $33.4009.
Using national GPCIs of 1.000 gives approximately $29.06. This amount represents a national Medicare payment calculation example. Actual Medicare payment varies according to geographic practice cost adjustments.
The $29.06 amount should not be treated as universal reimbursement. Commercial payer reimbursement can differ substantially from Medicare payment rates.
CMS also updates its Physician Fee Schedule files during the year. Therefore, users should verify current values before making payment decisions.
Common 97110 cpt code Billing Mistakes
1. Reporting 97110 for General Exercise
Not every exercise performed during therapy automatically supports 97110.
The record should establish the therapeutic purpose and skilled nature of the intervention.
2. Ignoring Actual Treatment Time
Because 97110 is a timed service, incorrect unit calculation can lead to underbilling, overbilling, or claim discrepancies.
3. Confusing Total Treatment Time With Timed Treatment Time
Untimed services should not simply be added to timed treatment minutes when calculating timed units.
CMS specifically distinguishes total treatment time from timed code treatment minutes.
4. Using a Modifier Without Checking the Applicable Rule
GP, CQ, KX, 59, and other modifiers serve different purposes.
Adding a modifier because it “usually works” is not a compliant coding methodology.
5. Insufficient Skilled Documentation
A note that only lists exercises and total minutes may not adequately demonstrate why skilled therapy was necessary.
6. Failing to Connect Exercise to Functional Goals
The documentation should make the relationship between the patient’s impairment, intervention, and therapeutic objective understandable.
7. Ignoring Payer-Specific Requirements
Medicare rules should not automatically be applied to every commercial payer.
Authorization, modifier, medical necessity, unit, and documentation requirements may differ by payer.
What Can Cause a 97110 cpt code Denial?
Common denial scenarios can include:
- Insufficient documentation
- Lack of demonstrated medical necessity
- Unsupported units
- Incorrect timed-unit calculation
- Missing required therapy modifier
- Incorrect use of CQ or KX when Medicare requirements apply
- NCCI-related coding conflicts
- Inappropriate modifier use
- Services inconsistent with the documented plan of care
- Coverage or authorization issues
- Diagnosis or claim information that does not support the service
- Documentation that does not establish skilled intervention
CMS’s 2026 Recovery Audit Contractor topic specifically identifies therapy claims involving 97110 and other therapy codes for review of medical necessity, coding guidelines, documentation, and appropriate use of KX.
How Can 97110 cpt code Denials Be Reduced?
A practical review process should include:
Before claim submission:
- Confirm that the intervention is accurately described by 97110 cpt code.
- Verify documented treatment minutes.
- Calculate timed units using the applicable payer methodology.
- Confirm the service is supported by the treatment plan and clinical goals.
- Review required therapy modifiers.
- Check applicable NCCI edits.
- Verify payer-specific authorization and coverage requirements.
- Confirm that documentation supports medical necessity and skilled care.
This approach addresses the major areas that can cause discrepancies between the clinical record and the claim.
97110 Coding Example: Single Service
A therapist provides 25 minutes of documented therapeutic exercise directed toward a patient’s documented strength and range-of-motion deficits.
Under the Medicare timed-code framework, 25 total timed minutes falls within the range supporting two timed units.
The claim would therefore be evaluated for 2 units of 97110, assuming the service otherwise meets applicable coverage, medical necessity, documentation, and coding requirements.
CMS uses a similar 25-minute 97110 example when explaining allocation of timed therapy units.
97110 Coding Example: Multiple Therapy Services
A therapy session includes:
- 18 minutes of 97110
- 13 minutes of 97140
- 10 minutes of 97116
- 8 minutes of an additional timed modality
Total timed treatment time is 49 minutes.
Under the Medicare framework, 49 minutes supports three timed units. CMS’s example allocates one unit each to 97110, 97140, and 97116 based on the individual 15-minute blocks and remaining minutes.
This demonstrates why coders should not simply divide each individual service’s minutes by 15 and round independently. The total timed treatment time and allocation methodology matter.
97110 and Home Exercise Programs
A home exercise program does not automatically mean every exercise instruction should be separately reported as 97110 cpt code.
The home exercise program is included in guidance from CMS as part of therapy plan of care and home exercise is discussed as the person transitions to being able to do them alone. When relevant to the documentation, the skilled role of therapy needs to be shown and appropriate progression.
The key question is whether the service provided during the encounter meets the requirements of the code and applicable payer policy.
97110 cpt code and Medicare in 2026
For Medicare, 97110 is subject to the broader outpatient therapy framework.
Important considerations include:
- Timed-code unit calculation
- Medical necessity
- Plan of care requirements
- Appropriate therapy modifiers
- PTA/OTA modifier requirements when applicable
- KX threshold requirements
- NCCI coding edits
- Documentation supporting skilled therapy
For 2026, CMS identifies $2,480 as the KX threshold for PT and SLP services combined and $2,480 for OT services. CMS also identifies $3,000 as the targeted medical review threshold for 2026.
These figures are Medicare-specific and should not be presented as universal commercial insurance rules.
Audit Considerations for 97110 cpt code
An audit of 97110 should examine the relationship between the clinical record and the claim.
A reviewer may reasonably look for evidence that:
- The diagnosis or condition supports the therapy.
- The treatment plan identifies appropriate goals.
- The intervention was therapeutic rather than simply recreational exercise.
- The therapist’s skill was necessary.
- Treatment time supports reported units.
- Each reported service is distinguishable when multiple therapy codes are billed.
- Required modifiers are supported.
- Documentation supports continued treatment where applicable.
- Medicare-specific requirements were followed when Medicare was the payer.
A useful internal audit question is:
Would an independent reviewer know from the documentation what was done, why, how long and why skilled therapy was a requirement?
If the answer is no, the record may require further review before the claim is submitted.
Key Takeaways
Key Takeaways
The 97110 CPT is for therapeutic exercise that is timed to meet goals like strength, endurance, range of motion, and flexibility.
The factors which are most significant in coding are:
- The 97110 cpt code is a 15 minute timed therapeutic procedure.
- The intervention should have a documented therapeutic purpose.
- Treatment time must support the units reported.
- Medicare uses a total timed treatment-minute methodology for outpatient therapy services.
- Untimed treatment time should not be incorrectly added to timed-code minutes.
- There are specific purposes for Medicare therapy modifiers (GP, CQ and KX) that should not be used interchangeably.
- Modifier 59 should only be used in a circumstance where the applicable circumstances for the code support a separation of the procedure.
- Reimbursement will be dependent on the different payers and payment methods.
- Requirements for Medicare should not be taken as a given for commercial insurance.
- Final claims should be submitted with current NCCI, Medicare and payer and fee-schedule rules in place.
The best way to code is to begin with the actual service documented, and then check the documentation, medical necessity, coverage and modifiers and then calculate the units based on the applicable payer methodology, and determine if the service is accurately represented by 97110.
