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.
