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Understanding CPT 97110: Strength, Flexibility, and Accurate Billing

When it comes to physical therapy services, accurate billing is just as important as quality care. One of the most commonly used and often misunderstood codes in outpatient rehab settings is CPT 97110. This code refers to therapeutic exercises and is widely used for strengthening, endurance training, and flexibility activities.

Understanding the 97110 CPT code not only helps providers improve documentation and ensure appropriate reimbursement but also avoids claim denials that stem from vague or insufficient coding.

In this article, we’ll break down the definition, appropriate use, documentation requirements, billing nuances, and best practices associated with CPT 97110.

What is CPT 97110?

97110  Therapeutic exercises to develop strength, endurance, range of motion, and flexibility; each 15 minutes

This code is used for therapeutic exercises that are part of a patient’s rehabilitative plan. It’s commonly used by physical therapists (PTs), occupational therapists (OTs), and sometimes chiropractors or other rehab specialists.

These exercises may include:

  • Strengthening exercises (e.g., resistance band or weight training)
  • Range of motion activities (e.g., stretching joints or muscles)
  • Endurance training (e.g., biking or treadmill walking for stamina)
  • Flexibility enhancement (e.g., yoga-type movements or passive stretching)

The 97110 CPT code applies to interventions that aim to improve the functional limitations resulting from illness, injury, or surgery.

Key Requirements for Using 97110 CPT Code

To bill for CPT 97110 correctly, there are specific criteria that must be met:

1. One-on-One Interaction

97110 is a timed, one-on-one code. This means the provider must be physically present and actively involved with the patient during the treatment.

Group therapy or unsupervised exercises cannot be billed under this code.

2. Active Therapeutic Purpose

The activity must be goal-directed and aimed at restoring or improving:

  • Muscle strength
  • Joint range of motion
  • Functional endurance
  • Flexibility

General wellness or fitness sessions do not qualify.

3. Medically Necessary

There must be a clear medical reason for providing the therapeutic exercises. This includes:

  • Post-surgical rehab
  • Neuromuscular injuries (e.g., stroke, MS)
  • Musculoskeletal dysfunctions (e.g., arthritis, joint instability)
  • Recovery from fractures or soft tissue injuries

The therapist’s clinical documentation must support why the exercises are needed.

Proper Documentation for 97110 CPT Code

Insurers require thorough documentation to support the use of this code. At a minimum, the note should include:

  • Type of exercise performed (e.g., quad strengthening with resistance bands)
  • Anatomical area targeted (e.g., right lower extremity)
  • Purpose of the exercise (e.g., increase knee flexion post-ACL surgery)
  • Duration and intensity (e.g., 15 minutes, 3 sets of 10 reps)
  • Patient response to the treatment

Example Note:

“Patient performed isometric quad sets and straight leg raises with 5 lbs ankle weight to improve quadriceps strength and knee stability post-total knee arthroplasty. One-on-one supervision provided. Completed 3 sets x 10 reps in 15-minute session. Tolerated well with no adverse effects.”

Timed Code Guidelines: Understanding the 8-Minute Rule

Since CPT 97110 is a time-based code, you must follow CMS’s 8-minute rule when billing multiple units. For practices considering outsourcing medical billing services, ensuring that billing partners understand these time-based rules is crucial for accurate reimbursement.

Time Spent (Minutes) Units to Bill
8–22 mins 1 unit
23–37 mins 2 units
38–52 mins 3 units
53–67 mins 4 units

So, if you provide therapeutic exercises for 20 minutes, you can bill 1 unit of 97110.

Always round to the nearest 15-minute increment, ensuring documentation supports the time spent.

Common Mistakes to Avoid with 97110 CPT Code

Despite its frequent use, 97110 is also one of the most scrutinized codes. Avoid these common pitfalls:

Vague or Non-Specific Documentation

Simply writing “therapeutic exercise” is not enough. Be specific about what was done, why, and how the patient responded.

Billing Without Justification

Don’t bill 97110 for exercises that don’t directly support a therapeutic goal related to the patient’s diagnosis.

Group or Self-Directed Activities

If the therapist isn’t directly involved with the patient during the session, 97110 should not be billed. Use 97150 (group therapy) if appropriate.

Overbilling Time

Be cautious not to exaggerate time. Only bill for time spent directly with the patient performing skilled therapy tasks.

Appropriate Diagnoses That Support CPT 97110

While CPT codes describe what was done, ICD-10 codes describe why. To justify 97110, it must be linked with a relevant diagnosis, such as:

  • M54.5 – Low back pain
  • M25.561 – Pain in right knee
  • S83.511A – Sprain of ACL, right knee, initial encounter
  • M62.81 – Muscle weakness (generalized)
  • Z47.89 – Encounter for orthopedic aftercare
  • M19.90 – Osteoarthritis, unspecified site

The diagnosis should support medical necessity and clearly relate to the therapy goals.

Modifier Use with CPT 97110

Depending on payer requirements and context, you may need to append modifiers:

Modifier GP

Indicates services were delivered under a physical therapy plan of care.

Modifier KX

Used when you are exceeding Medicare therapy thresholds, and documentation supports medical necessity.

Modifier 59

To distinguish 97110 from other similar services rendered during the same session. Use with caution and proper justification.

When to Use 97110 vs. Other Therapy Codes

It’s important to know when not to use 97110. For example:

  • 97112 – Neuromuscular reeducation (for balance, coordination, proprioception)
  • 97530 – Therapeutic activities (focus on functional tasks, like stair climbing or lifting)
  • 97116 – Gait training (for walking patterns or assistive device use)

97110 CPT code should only be used when the primary focus is on improving strength, endurance, flexibility, or range of motion, not on balance or functional mobility.

Reimbursement for CPT 97110

The average Medicare reimbursement for CPT 97110 (as of 2024) is approximately $27–$32 per unit, depending on your locality and facility status. Private payers may reimburse at different rates.

Tip: Always verify payer-specific rules for unit limits, prior authorization requirements, and documentation audits.

Using 97110 in Telehealth and Remote Settings

Post-COVID, many providers ask: Can I bill 97110 for telehealth?

Medicare and several commercial payers temporarily allowed this during the public health emergency (PHE). However, as rules evolve, you must:

  • Confirm payer policies
  • Document therapist interaction during the session
  • Ensure HIPAA compliance

As of 2025, not all payers allow 97110 via telehealth. Always verify with insurance plans.

The Role of Billing Services in CPT 97110 Accuracy

With physical therapy claims increasingly under scrutiny, many practices benefit from outsourcing to professional medical billing services. These experts ensure that 97110 CPT code usage aligns with payer requirements, reduces errors, and maximizes reimbursement.

Billing companies can:

  • Review therapist notes for compliance
  • Monitor unit usage and modifier accuracy
  • Reduce claim denials and appeals
  • Assist with payer audits

Final Thoughts

The 97110 CPT code is a foundational part of rehab therapy billing. However, it requires careful attention to detail, clinical documentation, and coding compliance. By ensuring:

  • One-on-one care is delivered,
  • Medical necessity is clearly documented,
  • Appropriate time and modifiers are used,
    you can reduce denials and improve revenue integrity.

Whether you’re a solo therapist, part of a large practice, or working with a billing partner, mastering 97110 is essential for delivering quality care and getting paid accurately for your work. Understanding how to avoid issues like the CO-50 Denial Code, which indicates services not deemed medically necessary, is also critical to ensure clean claims and proper reimbursement.

97110 CPT code, physical therapy billing, therapeutic exercises CPT

97110 CPT code covers therapeutic exercises for strength, flexibility, and range of motion. Learn billing tips, documentation, and compliance essentials.

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