CPT Code 97110: Complete Guide to Therapeutic Exercise Billing & Compliance

What is CPT Code 97110?

CPT code 97110 represents therapeutic exercise procedures designed to develop strength, endurance, range of motion, and flexibility. As one of the most frequently billed physical therapy codes, it's also one of the most scrutinized by payers and auditors.

This comprehensive guide breaks down everything you need to know about 97110 CPT code requirements, documentation standards, and compliance best practices to protect your practice from denials and audits.

CPT 97110 Definition and Key Components

According to the American Medical Association (AMA), CPT 97110 is defined as:

“Therapeutic procedure, 1 or more areas, each 15 minutes; therapeutic exercises to develop strength and endurance, range of motion and flexibility”

Key Elements of 97110:

• Time-based code: Billed in 15-minute units
• Direct contact required: One-on-one patient interaction
• Active participation: Patient must actively perform exercises
• Skilled service: Requires clinical decision-making and expertise

When to Use CPT Code 97110

Appropriate use cases for 97110 include:

• Progressive resistance exercises for strength building
• Active range of motion exercises
• Flexibility and stretching programs
• Endurance training activities
• Postural exercises
• Balance activities (when focused on strength/coordination)

Do NOT use 97110 for:

• Passive range of motion (use 97140 instead)
• Gait training (use 97116)
• Neuromuscular re-education (use 97112)
• Group therapy sessions (use 97150)

Documentation Requirements for CPT 97110

Proper documentation is critical for 97110 CPT code compliance. Your records must demonstrate:

1. Medical Necessity

• Clear functional deficits related to strength, ROM, or endurance
• How these deficits impact daily activities
• Why skilled therapy is required vs. home exercise program

2. Specific Exercise Details

• Type of exercise: Be specific (e.g., “seated knee extensions” not just “leg exercises”)
• Parameters: Sets, reps, resistance level, hold times
• Progression: How exercises were modified based on patient response
• Patient performance: Quality of movement, compensations noted

3. Time Documentation

• Total time spent on 97110 activities
• Start and stop times when multiple codes are billed
• Clear delineation between different CPT codes performed

4. Clinical Decision-Making

• Why specific exercises were chosen
• Modifications made during treatment
• Patient education provided
• Assessment of patient response

Common 97110 Billing Mistakes to Avoid

1. Insufficient Documentation

Problem: Generic notes like “therapeutic exercises performed x 30 minutes”

Solution: Document specific exercises, parameters, and patient response

2. Billing for Non-Skilled Services

Problem: Billing 97110 for exercises patient can perform independently

Solution: Document why skilled intervention is necessary for safety, effectiveness, or progression

3. Incorrect Time Calculations

Problem: Rounding up units or including setup/rest time

Solution: Follow the 8-minute rule precisely and document actual treatment time

4. Mixing Codes Inappropriately

Problem: Billing 97110 for activities better coded elsewhere

Solution: Understand distinctions between therapeutic codes and bill most appropriate code

The 8-Minute Rule for CPT 97110

Since 97110 is a time-based code, you must follow Medicare's 8-minute rule:

• 8–22 minutes = 1 unit
• 23–37 minutes = 2 units
• 38–52 minutes = 3 units
• 53–67 minutes = 4 units

Important: When billing multiple time-based codes, total all timed minutes first, then determine total units before allocating to specific codes.

Payer-Specific Requirements for 97110

Medicare

• Requires demonstration of functional improvement
• Expects skilled intervention documentation
• May limit units based on diagnosis

Commercial Payers

• Often have visit or unit limits
• May require pre-authorization after certain number of visits
• Some require specific outcome measures

Workers' Compensation

• Typically requires work-related functional goals
• May have state-specific documentation requirements
• Often scrutinizes duration of care

Best Practices for 97110 Compliance

1. Create Exercise Templates

Develop templates for common diagnoses that include:

• Evidence-based exercise progressions
• Clear documentation prompts
• Outcome measure tracking

2. Regular Documentation Audits

Review charts monthly to ensure:

• Exercise specificity meets standards
• Time documentation is accurate
• Medical necessity is clearly established

3. Staff Training

Provide ongoing education on:

• Proper exercise documentation
• Time tracking requirements
• Payer-specific guidelines

4. Technology Solutions

Consider implementing compliance software that can:

• Flag incomplete documentation
• Verify time calculations
• Ensure medical necessity criteria are met

How Brellium Helps with 97110 Compliance

Managing CPT 97110 compliance across multiple therapists and locations can be overwhelming. Brellium's AI-powered platform automatically reviews 100% of your therapy documentation to:

• Verify exercise specificity: Flags generic documentation that could trigger denials
• Validate time calculations: Ensures 8-minute rule compliance across all timed codes
• Check medical necessity: Confirms functional deficits and skilled need are documented
• Identify billing risks: Catches common errors before claims submission

By automating compliance checks, Brellium helps therapy practices reduce audit risk, minimize denials, and maintain consistent documentation quality across all providers.

Learn more: Brellium's Clinical Compliance Platform

Frequently Asked Questions About CPT 97110

Can 97110 be billed with other therapy codes?

Yes, 97110 can be billed with other CPT codes during the same session. However, you must clearly document the time spent on each distinct service and ensure activities don't overlap.

What's the difference between 97110 and 97530?

97110 focuses on exercises for strength, ROM, and flexibility. 97530 (therapeutic activities) involves functional tasks that incorporate multiple parameters simultaneously, like lifting, carrying, or reaching activities.

How many units of 97110 can I bill per session?

There's no absolute limit, but payers expect reasonable amounts based on patient tolerance and medical necessity. Most sessions include 2–4 units of 97110, often combined with other interventions.

Do I need to document each individual repetition?

While you don't need to count every rep, you should document exercise parameters (sets, reps, resistance) and any modifications made during treatment.

Conclusion

Proper use and documentation of CPT code 97110 is essential for therapy practice compliance and financial health. By understanding requirements, avoiding common mistakes, and implementing strong documentation practices, you can confidently bill for therapeutic exercises while minimizing audit risk.

Remember: when it comes to 97110 documentation, specificity is your best defense. Document what you do, why you do it, and how the patient responds—every single time.

Additional Resources

• APTA Documentation Guidelines
• CMS Therapy Services Documentation Requirements
• AAPC CPT 97110 Coding Guidelines