CPT Code 97110: Therapeutic Exercise, Each 15 Minutes

CPT code 97110 reports a direct, skilled therapeutic procedure using exercise to develop strength, endurance, range of motion, and flexibility. It belongs to the physical medicine and rehabilitation category — not the E/M family — and has no MDM requirement. 

Code selection depends on the therapeutic purpose of the exercise and actual timed minutes of skilled one-on-one intervention, reported in 15-minute units under Medicare’s timed-code methodology.

97110 is one of the highest-volume therapy codes billed to Medicare, and its audit profile reflects that. 

Palmetto GBA’s Q1 2026 targeted review of 97110 found a 17% claim denial rate in the reviewed population — with 46% of denials attributed to insufficient medical necessity and 35% to missing or incomplete documentation. 

OIG’s broader PT audit estimated $367 million in noncompliant outpatient physical therapy payments during its audited period.

What does CPT code 97110 cover?

The essential reference facts for 97110 billing.

Detail	CPT 97110
Description	Therapeutic exercise to develop strength, endurance, ROM, flexibility — each 15 min
Category	Physical Medicine and Rehabilitation — Therapeutic Procedures
Patient type	N/A (not E/M, no new/established distinction)
MDM level	N/A (not an E/M code)
Time	Timed per 15 min; Medicare 8-min minimum rule applies
Common modifiers	GP, GO, CQ, CO, KX, 59, 95
Medicare rate	~$29.06/unit national baseline (2026)
Commonly compared with	CPT 97530

The clinical purpose — not the name of the exercise or the equipment used — drives 97110 selection. 

The intervention must target strength, endurance, ROM, or flexibility development. Balance and proprioception retraining falls under 97112, and dynamic functional activities under 97530.

When should you use CPT 97110?

The code applies when a qualified therapist delivers skilled therapeutic exercise targeting specific physical impairments.

Use CPT 97110 when

• The intervention targets strength, endurance, range of motion, or flexibility development
• The therapist provides direct, skilled one-on-one treatment (not mere supervision of independent exercise)
• Actual skilled intra-service time reaches at least 8 minutes under Medicare’s timed methodology
• The exercise is medically necessary and linked to documented functional impairments

Consider a patient six weeks after rotator-cuff repair with objectively reduced shoulder ROM and weakness interfering with dressing and overhead reaching. 

The PT provides 23 minutes of direct, skilled graded active-assisted ROM and resisted strengthening, adjusting resistance and technique based on the patient’s response. 

With 23 minutes of total timed treatment (and no other timed codes), two units of 97110 are supported under Medicare’s timed methodology.

When not to use it

• The patient performs independently mastered exercises with only supervisory presence — independent exercise is not billable skilled treatment
• The primary purpose is balance/proprioception/coordination retraining — consider 97112
• The intervention is dynamic functional activity for real-world task performance — consider 97530
• Total timed treatment is fewer than 8 minutes — Medicare does not support a unit
• The exercises are general wellness or maintenance rather than skilled therapy addressing a specific impairment

How is CPT 97110 selected?

97110 has no MDM pathway. Selection depends on the therapeutic purpose of the exercise and Medicare’s timed-code unit calculation.

Timed-unit methodology

For Medicare, first add the minutes of all timed therapy codes furnished by one discipline on that date, determine the maximum units, then allocate those units among the individual codes based on actual minutes. 

Do not round each code independently.

Total timed treatment minutes	Maximum Medicare units
0-7	0 (not billable)
8-22	1
23-37	2
38-52	3
53-67	4

The 8-minute minimum is absolute — fewer than 8 total timed minutes cannot support a billable unit. And the calculation applies to total timed minutes across all timed codes for that discipline, not to 97110 in isolation.

What counts as treatment time

Count only skilled intra-service time during which the qualified therapist is directly furnishing the intervention. 

Medicare guidance allows including intra-service assessment integral to treatment — for example, assessing shoulder strength before progressing the exercise program.

Do not count changing clothes, waiting for equipment, rest periods without skilled treatment, independent exercise, separate documentation time, or toileting. 

A clinician cannot count the same clock minutes twice for two direct one-on-one therapeutic procedures.

What documentation supports CPT 97110?

For therapy codes, the documentation burden centers on proving skilled treatment actually occurred — not just that exercises were performed.

The note should include

• Specific intervention/exercises performed and their parameters (sets, reps, resistance, technique)
• The functional deficit the exercise addresses (e.g., reduced shoulder ROM limiting overhead reaching)
• Actual timed treatment minutes (not rounded to 15-minute blocks, not documented as units)
• What makes the treatment skilled — cueing, modification, progression, safety monitoring, or intra-service assessment
• Patient response and functional progress
• Connection to the treatment plan and goals
• Clinician signature and credentials

Medicare contractor guidance explicitly warns against documenting only “ther ex performed” without identifying what was done, why it was medically necessary, or what the therapist’s skilled contribution was. 

Whole-session “time in/time out” entries do not establish actual skilled treatment minutes and should not substitute for real timed documentation.

How much does CPT 97110 reimburse?

Payment is per unit, and multiple payment adjustments can stack on the same claim.

Payment type	2026 rate per unit
Medicare national baseline	~$29.06
Medicare after MPPR (2nd+ therapy service)	Reduced PE component
PTA/OTA services (CQ/CO modifier)	85% of otherwise applicable amount
Commercial payers (median)	~$31.35
Medicaid	Varies by state

Medicare rate from CMS 2026 PFS national baseline (0.87 total RVU × ~$33.40 conversion factor). Commercial median from Transparency-in-Coverage data (Reddenda, 2026).

Medicare’s therapy Multiple Procedure Payment Reduction (MPPR) applies when more than one therapy service is furnished the same day — the service with the highest practice-expense component pays at 100%, and subsequent services receive a 50% reduction on their PE component only. 

The entire 97110 payment is not halved; only the PE portion of additional units faces the reduction.

The 2026 KX threshold is $2,480 for PT/SLP combined and $2,480 for OT. Beyond that threshold, KX must be appended to indicate continued medical necessity, and the $3,000 targeted medical review threshold remains through 2027.

Which modifiers apply to CPT 97110?

Therapy codes carry a unique modifier landscape compared to E/M or psychotherapy.

Modifier	When it applies
GP	Service furnished under a physical therapy plan of care
GO	Service furnished under an occupational therapy plan of care
CQ	PT service furnished in whole or qualifying part by a PTA (pair with GP) — 85% payment
CO	OT service furnished in whole or qualifying part by an OTA (pair with GO) — 85% payment
KX	Required when incurred therapy expense exceeds 2026 KX threshold of $2,480 and continued medical necessity is documented
95	Telehealth — CMS requires modifier 95 for outpatient therapy furnished via eligible telehealth
59	Only when a current NCCI indicator-1 edit exists, and genuinely distinct services are documented

Modifier 25 does not belong on 97110 — it belongs on a separately reported E/M code when that E/M is significant and separately identifiable from the therapy. OIG has specifically challenged E/M claims billed alongside therapy when no separate E/M was documented.

CPT 97110 vs. 97530 — which one fits?

The 97110/97530 confusion is one of the oldest debates in therapy coding. Both are timed therapeutic procedures, and the distinction turns on the therapeutic objective — not the exercise equipment or how “functional” the movement looks.

Feature	CPT 97110	CPT 97530
Service	Therapeutic exercise	Therapeutic activities
Patient type	N/A	N/A
MDM	None	None
Selection criterion	Exercise for strength, endurance, ROM, flexibility	Dynamic activities for functional performance
Typical examples	Graded strengthening, ROM stretching, endurance training	Lifting/carrying, transfers, task simulation
Medicare rate (2026)	~$29.06/unit	~$35.07/unit

Choose 97110 when the therapeutic purpose is strength, endurance, ROM, or flexibility development.

Choose 97530 when the intervention is a dynamic functional activity designed to improve real-world functional performance — lifting, carrying, reaching, transferring, or work simulation.

Medicare contractor guidance specifically warns against selecting the code based on reimbursement amount. A $6/unit difference might tempt 97530 selection, but the treatment goal — not the fee — should determine the code. 

An exercise can look functional without automatically becoming 97530, and lifting can be either strengthening (97110) or therapeutic activity (97530) depending on the documented therapeutic objective.

What billing errors should you avoid with CPT 97110?

Six errors drive the majority of 97110 denials and audit exposure.

1. Billing a unit with fewer than 8 total timed minutes

 Medicare’s timed-code methodology does not support a unit when total timed therapy is under 8 minutes. Record actual minutes and apply the unit table after summing all timed codes.

2. Calculating each timed code independently 

Sum all timed-code minutes for the discipline first, determine total units, then allocate. Independent rounding of each code can generate more units than the patient’s combined treatment supports.

3. Counting rest, waiting, setup, or independent exercise 

Those activities do not represent direct skilled intra-service treatment. Exclude changing, waiting for equipment, resting, toileting, and unsupervised independent exercise from the time count.

4. Generic notes without skilled-intervention detail 

“Ther ex performed” fails to establish what was done, why it met 97110, or the therapist’s skilled contribution. Link exercises to measurable deficits and document parameters, progression, and patient response.

5. Billing routine home-exercise-program practice as skilled treatment 

Once a patient has mastered exercises and performs them independently, a therapist’s nearby presence does not make the activity billable 97110. Bill only actual skilled instruction, progression, or assessment.

6. Wrong personnel or missing modifiers 

OIG has settled cases involving 97110 furnished by unlicensed aides. Verify provider qualifications, and always pair CQ/CO with the appropriate discipline modifier when PTA/OTA services apply.

Frequently asked questions about CPT 97110

Here are some frequently asked questions about CPT 97110: