The Medicare eight-minute rule for therapy

For owners and billing staff of OT, PT and SLP practices treating children, adults or both: Medicare adds a day’s minutes on 15-minute timed codes, so 8 to 22 minutes bill one unit, 23 to 37 two, 38 to 52 three. Untimed codes bill one unit. Other payers may count each code at its own midpoint, so ask each payer.⁠^1,2,3

What is the Medicare eight-minute rule for therapy billing?

It is Medicare’s method for turning the minutes a patient spends in 15-minute timed therapy services on one day into billable units: count the direct treatment minutes, add them across every timed code, and read the units from the manual’s table. The Claims Processing Manual, chapter 5, section 20.2, sets it out, and says that when only one service is furnished in a day, less than 8 minutes of it is not billed.⁠¹ CMS describes 8 minutes as passing the midpoint of a 15-minute unit, more than half of it, and calls that threshold the 8-minute rule.⁠^5,8

It governs Medicare Part B outpatient therapy claims. Physical therapists, occupational therapists and speech-language pathologists in private practice bill their Medicare Administrative Contractor with HCPCS and CPT codes, and hospitals do the same for their outpatients, among the other providers the manual lists.⁠¹¹ Each therapy line carries the modifier for the discipline of the plan of care: GP for physical therapy, GO for occupational therapy and GN for speech-language pathology.⁠¹³

What does Medicare’s unit table say for each range of minutes?

The table covers one to eight units, and the manual says the same pattern continues past two hours; it prints no row for fewer than 8 minutes, and its rule that a service under 8 minutes is not billed fills that row.⁠¹ Read the day’s total timed minutes, not the minutes of any one code, against it when more than one timed code was furnished.

Which therapy codes are timed and which are untimed?

The code’s descriptor decides: a timed code names an interval, such as each 15 minutes, an initial 30 minutes or a first hour, and an untimed code describes a service with no time in it and is generally reported as a single unit.⁠³ CMS’s yearly therapy code list does not settle the question, because it marks codes as always or sometimes therapy, and the chart in section 20.2 dropped its timed column, saying the notation does not change the units allowed.⁠^1,12

CMS’s own examples treat 97110 therapeutic exercise, 97112 neuromuscular reeducation, 97116 gait training, 97140 manual therapy, 97530 therapeutic activities and 97535 self-care training as 15-minute codes.⁠^1,5 CMS lists evaluations, re-evaluations, supervised modalities and group therapy among the untimed codes that bill one unit, and the NCCI manual defines the supervised modalities as codes 97010 through 97028.⁠^5,14 ASHA states that most codes speech-language pathologists report are untimed and bill once a day, including 92507 individual treatment and 92526 swallowing treatment.⁠^3,6,7

Some timed codes run on longer intervals. Medicare reports 96105 aphasia assessment in one-hour units, ASHA lists 96125 standardized cognitive testing as timed per hour, and Medicare expects the whole 2-hour or 1-hour period for the return-to-work codes 97545 and 97546.⁠^6,15 A payer’s own list can help too: UnitedHealthcare’s commercial policy lists the physical medicine codes it calls timed codes, among them 97110, 97112, 97129, 97130, 97140, 97530, 97533 and 97535.⁠¹⁶ The OT procedure codes guide maps the codes an OT practice bills.

How are units assigned among codes when the minutes are split?

By the manual’s order: the day’s total sets how many units there are, each code furnished for 15 minutes or more takes its full units first, and any unit left goes to the code with the most leftover minutes.⁠¹ The steps below follow section 20.2 and its five examples.

1. Total the timed minutes. Add the direct minutes of every 15-minute timed code furnished that day, including any code that ran under eight minutes; the manual says no minute before the eighth is dropped from the count.⁠¹
2. Read the cap. Find the total in the table. The units on the claim cannot exceed it, however many codes were furnished.⁠¹
3. Give full units first. A code furnished for 15 minutes or more gets at least one unit, 30 minutes or more at least two, and so on.⁠¹
4. Assign the rest by leftover minutes. Compare the minutes each code has left after its full units and give the next unit to the larger; in the manual’s example, 33 minutes of 97110 and 7 of 97140 bill 97110 twice and 97140 once, because 7 leftover minutes beat 3.⁠¹
5. Choose on a tie. When codes have equal minutes, either may take the extra unit, and the day’s minutes never all go to one code when another ran more than 15 minutes.⁠¹
6. Record what you could not bill. A timed service that earns no unit still goes in the treatment note, as the manual’s ultrasound example shows.⁠^1,4

Two of the manual’s examples show the cap at work. In one, 24 minutes of 97112 and 23 of 97110 total 47 minutes, which is three units, so 97112 bills two and 97110 one; in another, four codes run 18, 13, 10 and 8 minutes for 49 minutes in all, still three units, so the three longest bill and the 8 minutes of ultrasound go in the note unbilled.⁠¹

Do several codes under eight minutes each add up to a unit?

Yes, under Medicare. When two or more timed services each run 7 minutes or less but together reach 8 minutes, one unit is billed for the service that ran longest; with 7 minutes each of three codes, 21 minutes in all, one unit is billed and the clinician chooses which code it goes to.⁠¹ The reverse also holds: a single code furnished alone for 7 minutes bills nothing.⁠¹

Medicare expects each unit to average 15 minutes of direct contact, and the manual says a practice that consistently bills units of fewer minutes should be highlighted for review; it describes its table as help in rounding time into 15-minute increments, so the 8-minute floor rounds the last unit and is not a target for every unit.⁠¹

How does the CPT midpoint method differ from Medicare’s?

It counts each code by itself and reports a unit each time the midpoint of the code’s interval is passed, without adding the day’s minutes together. The American Medical Association publishes the CPT manual, and APTA reads its time guidelines as requiring the midpoint of an interval to be exceeded before a unit is billed, with no instruction to total minutes across codes.⁠² ASHA describes the same convention as a unit reached once more than half the stated time has passed, and calls it a separate methodology from Medicare’s that should not be used interchangeably with it.⁠³

With one timed code, the two methods give the same answer: 8 to 22 minutes is one unit either way, and 23 to 37 is two.⁠^1,3 They part when the minutes are spread across codes. Ten minutes each of two codes is one unit under Medicare, since 20 total minutes falls in the one-unit range, and two units code by code; 22 minutes each of two codes is three units under Medicare, since 44 minutes falls in the three-unit range, and two code by code, since neither code reaches the midpoint of its second interval.⁠^1,2,3 Neither method bills more in every case; the result depends on how the minutes fall.

Do other payers use Medicare’s method or count each code?

Medicare Part B follows its own manual; every other payer follows what its policy or your contract says. APTA advises reviewing each payer’s policy to learn which method it follows, and notes that a contract term, such as one allowing a unit after five minutes, takes precedence over the general standards.⁠² Two published policies show the range:

• UnitedHealthcare commercial plans: the 2026 reimbursement policy states that, in alignment with CMS, at least 8 minutes are needed to bill one 15-minute unit, and it pays up to four timed codes, which it equates to one hour, per date of service for professionals of the same specialty, with a reconsideration request for more. It does not apply in the home or in a comprehensive inpatient or outpatient rehabilitation facility, or to Oxford plans.⁠¹⁶
• Washington Apple Health (Medicaid): the July 10, 2026 billing guide counts each 15 minutes of a timed code as one unit and each untimed code as one unit, and asks for start and end times for each timed code in the record.⁠¹⁷

The UnitedHealthcare note sets the minimum for one unit; ask how the plan splits a day’s minutes among codes. Washington’s passage defines a unit as each 15 minutes; ask how a partial 15 is counted. For a Medicare Advantage plan, a Medicaid managed care plan or TRICARE, find the rule in the plan’s provider manual or your agreement, and if neither states it, ask and keep the answer with the day and the name of the person who gave it. The TRICARE participation guide and the Medicaid enrollment guide cover joining those programs.

How do the two methods compare on the same session?

The table applies Medicare’s section 20.2 method and the code-by-code midpoint method to six hypothetical visits, three for children and three for adults, each with an untimed code alongside that bills one unit under either method.⁠^1,2,5 The minutes are inputs, not benchmarks. The table counts minutes only: the NCCI manual bars reporting two physical medicine services for the same 15-minute period, except a supervised modality, and its pair edits can bar or condition a combination of codes, so check the edit tables in effect for the date of service before a claim goes.⁠¹⁴

In three rows the methods agree; in two a code-by-code count bills one more unit, and in one Medicare’s total bills one more. Total treatment time adds the untimed minutes to the timed ones, 55 minutes for the first child, for example, and belongs in the note beside the timed total.⁠⁴ When a patient has individual treatment and a group on the same day, Noridian, the Medicare contractor for Jurisdiction F, says in its Rehabilitation Delivery Methods article (last updated July 11, 2025) that both may be billed under Medicare when CPT and Medicare requirements are met, provided the documentation keeps the group’s untimed minutes apart from the individual timed minutes, with modifier 59 used as appropriate.⁠¹⁸

What goes in the treatment note for timed and untimed minutes?

For Medicare, each treatment day’s note names every intervention, timed and untimed, in words a reviewer can match to the claim, records every timed service even when it is not billed, and gives two totals: total timed code treatment minutes and total treatment time.⁠⁴ Total treatment time adds the untimed minutes and leaves out time that is not billable, such as rest; the minutes of each intervention may be recorded, but a contractor may not require them, and the billed units must be consistent with the timed total.⁠⁴ The note also carries the signature and credentials of the professional who furnished or supervised the service and a list of everyone who contributed.⁠⁴

Other payers can ask for more. Washington’s Medicaid guide asks for start and end times for each timed code, and ASHA lists start and stop times among the elements of timed-service documentation when a payer, facility or organization requires them.⁠^3,17 The Benefit Policy Manual adds that state or local law, a profession’s guidelines or a practice’s own policy may be stricter than Medicare’s minimum.⁠⁴

Which minutes count as treatment time and which do not?

Only the minutes the patient is being treated. Count from the moment the therapist, or an assistant under supervision, is directly working with a patient who is already in the treatment area and ready to begin, and leave out pre- and post-service work, rest, toileting and time spent waiting for equipment or another treatment.⁠¹⁵

When two clinicians treat one patient together, the minutes count once: in the manual’s example, two people managing a patient in the parallel bars bill one unit of gait training for each 15 minutes.⁠¹⁵ The NCCI manual applies the same idea across codes, allowing one physical medicine service per 15-minute period, with supervised modalities the only exception.⁠¹⁴ Noridian adds that minutes a therapy aide provides or oversees do not count, even under a clinician’s supervision.⁠¹⁸

How do assistant minutes and the CQ and CO modifiers work?

Under Medicare, a physical therapy line furnished in whole or in part by a physical therapist assistant takes CQ beside GP, and an occupational therapy line furnished in whole or in part by an occupational therapy assistant takes CO beside GO; Medicare pays those lines at 85 percent of the amount it would otherwise pay, taking that reduction last.⁠¹³ The two assistant modifiers cover physical therapist assistants and occupational therapy assistants only.⁠¹³ For speech-language pathology, see the speech therapy CPT codes guide.

“In part” has a threshold, the de minimis standard: minutes an assistant furnishes on their own that do not exceed 10 percent of the service, or of a unit, do not trigger the modifier, and minutes the assistant furnishes together with the therapist count as the therapist’s.⁠^8,9 CMS’s billing examples set the order of work:

• Full units first. Each clinician’s full 15-minute blocks of a code earn their units, and an assistant’s full block takes the modifier.⁠⁵
• The final unit. If the therapist furnished 8 or more minutes of the last unit, it bills without CQ or CO whatever the assistant added; the regulations call 8 minutes more than the midpoint of a 15-minute code.⁠^5,9,10
• Two units left of one code. When the therapist and the assistant each furnished 9 to 14 minutes of it and the two total 23 to 28, one unit bills with the modifier and one without.⁠⁸
• Different codes. When one unit is left and the therapist and assistant worked on different codes, the code with more leftover minutes is billed, with the modifier only if those minutes were the assistant’s.⁠⁵
• Untimed codes. Group therapy and supervised modalities bill one unit, and the 10 percent standard decides whether that unit carries the modifier.⁠⁵

Supervision is a separate rule. In private practice, Medicare lets a PTA or OTA furnish services under the therapist’s general supervision, while an unenrolled therapist works under direct supervision.⁠^9,10 Read the state practice act’s supervision rule as well before scheduling an assistant alone.

Where does the eight-minute rule not apply?

It does not reach untimed codes, codes with longer intervals, Medicare Part A stays, home health under a home health plan of care, or payers that write their own rule.⁠^1,3,11

• Untimed codes: one unit, whatever the minutes.⁠¹
• Codes with longer intervals: ASHA’s guidance limits Medicare’s 8-minute rule to 15-minute codes, so the hour and two-hour codes above follow their own intervals.⁠^3,15
• Caregiver training: Medicare allows 97550 to be billed only when the full 30 minutes is furnished and each unit of 97551 only for a full 15, and treats the group code 97552 as untimed; ASHA notes other payers may still apply the CPT midpoint to those codes.⁠^3,12
• Part A stays: therapy during a covered Part A hospital or skilled nursing facility stay is bundled into that setting’s prospective payment, with no separate payment.⁠¹¹
• Home health: a home health agency codes outpatient therapy with HCPCS only for patients who are not homebound and so not under a home health plan of care.⁠¹¹
• Cost-based and all-inclusive settings: the HCPCS reporting requirement does not apply to critical access hospitals, paid on a cost basis, or to rural health clinics and federally qualified health centers, where therapy is in the all-inclusive rate.⁠¹¹
• Every other payer: the unit rule is the one in the payer’s policy or your contract, which may follow Medicare, follow the CPT midpoint or set its own.⁠^2,3

How do children’s Medicaid claims differ from adults’ Medicare claims?

The codes do not change with age; the payers and their limits do. In Washington’s program, eligible clients 20 and younger have unlimited outpatient rehabilitation, apart from 19- and 20-year-olds in its Medical Care Services program, while clients 21 and older have a short-term benefit with a limit per calendar year counted in units, 24 for physical therapy, which the guide equates to about 6 hours, and 6 for speech therapy, which it calls untimed visits.⁠¹⁷ What Medicaid owes a child under the federal screening and treatment benefit is covered in the EPSDT guide; ask each Medicaid program or plan, and each child’s commercial plan, which counting method it uses.

For an adult on Original Medicare Part B, the manual’s method applies to the claim the practice sends its Medicare contractor.⁠^1,11 For an adult in a Medicare Advantage plan, ask the plan which method it uses and keep the answer. Plans of care, the yearly KX threshold and coverage from the patient’s side are in the Medicare therapy coverage guide.

What should SLP practices know about timed minutes before 2027?

That most of their codes are untimed for now. Most speech-language pathology codes bill once a day whatever the minutes: 92507 individual treatment is untimed, as are 92526 swallowing treatment and the 92508 group code.⁠^3,6,7 Timed SLP codes include 96105 and 96125, counted per hour, and the cognitive intervention pair 97129 and 97130.⁠^3,6,15

That changes on January 1, 2027, when 92507 gives way to a family of treatment codes with a 30-minute base code and a 15-minute add-on.⁠^19,20 ASHA writes that, under the general CPT midpoint convention, clinicians may report the base code after 16 minutes, while CPT instructions, CMS rules and each payer’s policy can require something different; Medicare’s values come in its 2027 final rule, and other payers decide if and when to adopt the codes.⁠^19,20 Read that rule and your contractor’s guidance before the first 2027 claim; the full code map is in the speech therapy CPT codes guide.

Which billing errors put timed therapy units at risk?

Minutes that do not belong in the count, and units that do not match it. In Jurisdiction F, Noridian’s review findings for outpatient therapy name documentation that supports a change in units of service among the errors, beside codes such as 97110 and 97140 not supported by documentation or coding.⁠²¹ Check each claim against this list:

• Rounding each code up under Medicare: billing every code that passed 8 minutes without applying the day’s cap, which the total timed minutes set.⁠¹
• All units on one code: putting the day’s minutes on one code when another ran more than 15 minutes.⁠¹
• Counting time that is not treatment: setup, wrap-up, rest, toileting and waiting for equipment.⁠¹⁵
• Counting the same minutes twice: two clinicians billing the same time with one patient, or two physical medicine codes for one 15-minute period.⁠^14,15,18
• Group time billed as individual time: when a therapist divides attention among patients at once, each patient bills one unit of the untimed group code; Noridian adds that in hospital-based and independent outpatient therapy clinics, among other settings, patients cannot be treated concurrently, since a therapist may treat only one patient at a time.⁠^4,18
• Aide minutes: minutes a therapy aide provides or oversees do not count.⁠¹⁸
• Totals that do not match the units: the billed units must agree with the total timed minutes in the note.⁠⁴
• A pattern of short units: the manual says a practice that consistently bills units of fewer than 15 minutes should be highlighted for review.⁠¹
• Missing modifiers: GP, GO or GN on every Medicare therapy line, with CQ or CO paired to GP or GO when an assistant’s share passes the threshold.⁠^8,13

Pair edits are a separate check. The NCCI manual says some edits pair a timed code with another timed or untimed code, that modifier 59 or XU can bypass such an edit when the two services were furnished in different time intervals, and that correct coding is expected even where no edit exists; use the edit tables in effect for the date of service.⁠¹⁴

How do you work out units for a visit, step by step?

Fill one worksheet per patient per day as the session runs, total the minutes, then run them through the payer’s method in the calculation table. The worksheet holds both totals the Medicare note needs and every timed service, billed or not.⁠⁴

How do you turn the worksheet into units on the claim?

Copy each timed code into a row, work out its full 15-minute units and leftover minutes, then fill the column for the payer’s method. Under Medicare the total row’s cap comes from the unit table and the leftovers decide where the remaining units go; code by code, a leftover that passes the midpoint earns a unit.⁠^1,2

Which unit method does each type of payer use?

Original Medicare Part B uses the section 20.2 method; Part A stays and home health under a home health plan of care do not bill units this way; every other payer uses whatever its own policy or your contract states.⁠^1,2,11 The table sets out where to look and what to keep.

The payment explanation guide covers self-pay fees and good faith estimates.

How would one child’s and one adult’s visits be counted both ways?

Two hypothetical visits, worked with the rules above: a child’s under a commercial plan that counts each code at its midpoint, and an adult’s under Original Medicare with an assistant.⁠^1,2,5

How do you explain unit counts to patients and families?

Explain the method, not a promise about the bill: for timed codes, the payer turns treatment minutes into 15-minute units by its own rule, and under Medicare’s manual, time spent resting, waiting or setting up is not treatment time.⁠^2,15 When a parent compares two statements for sessions of the same length, the difference may come from how the minutes split across codes or from two payers’ methods, so show the minutes by code from the note rather than a general answer.

Say who reviews a question about a specific claim and when the family hears back, and keep the explanation of benefits beside the note when you check it. Wording for payment conversations, authorization and self-pay estimates is in the payment explanation guide, and the rate negotiation guide covers how per-unit and per-visit rates compare when a contract is reviewed.

Sources

1. Centers for Medicare & Medicaid Services. Medicare Claims Processing Manual, Chapter 5, Part B Outpatient Rehabilitation and CORF/OPT Services (§20.2, Reporting of Service Units With HCPCS, Rev. 3670, effective January 1, 2017; the manual’s own unit chart and Examples 1 to 5). Checked October 25, 2026.
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   “When reporting service units for HCPCS codes where the procedure is not defined by a specific timeframe (“untimed” HCPCS), the provider enters “1” in the field labeled units.”; “Several CPT codes used for therapy modalities, procedures, and tests and measurements specify that the direct (one on one) time spent in patient contact is 15 minutes.”; “A beneficiary received a total of 60 minutes of occupational therapy, e.g., HCPCS “timed” code 97530 which is defined in 15 minute units, on a given date of service. The provider would then report 4 units of 97530.”; “A beneficiary received a speech-language pathology evaluation represented by HCPCS “untimed” code 92521. Regardless of the number of minutes spent providing this service only one unit of service is appropriately billed on the same day.”; “When only one service is provided in a day, providers should not bill for services performed for less than 8 minutes.”; “1 unit: ≥ 8 minutes through 22 minutes 2 units: ≥ 23 minutes through 37 minutes 3 units: ≥ 38 minutes through 52 minutes 4 units: ≥ 53 minutes through 67 minutes 5 units: ≥ 68 minutes through 82 minutes 6 units: ≥ 83 minutes through 97 minutes 7 units: ≥ 98 minutes through 112 minutes 8 units: ≥ 113 minutes through 127 minutes”; “The pattern remains the same for treatment times in excess of 2 hours.”; “If a service represented by a 15 minute timed code is performed in a single day for at least 15 minutes, that service shall be billed for at least one unit. If the service is performed for at least 30 minutes, that service shall be billed for at least two units, etc. It is not appropriate to count all minutes of treatment in a day toward the units for one code if other services were performed for more than 15 minutes.”; “When more than one service represented by 15 minute timed codes is performed in a single day, the total number of minutes of service (as noted on the chart above) determines the number of timed units billed.”; “If any 15 minute timed service that is performed for 7 minutes or less than 7 minutes on the same day as another 15 minute timed service that was also performed for 7 minutes or less and the total time of the two is 8 minutes or greater than 8 minutes, then bill one unit for the service performed for the most minutes.”; “The expectation (based on the work values for these codes) is that a provider’s direct patient contact time for each unit will average 15 minutes in length. If a provider has a consistent practice of billing less than 15 minutes for a unit, these situations should be highlighted for review.”; “If more than one 15 minute timed CPT code is billed during a single calendar day, then the total number of timed units that can be billed is constrained by the total treatment minutes for that day.”; “Since the time for each service is the same, choose either code for 2 units and bill the other for 1 unit. Do not bill 3 units for either one of the codes.”; “Count the first 30 minutes of 97110 as two full units. Compare the remaining time for 97110 (33-30 = 3 minutes) to the time spent on 97140 (7 minutes) and bill the larger, which is 97140.”; “Bill the procedures you spent the most time providing.”; “You would still document the ultrasound in the treatment notes.”; “shall select one appropriate CPT code (97112, 97110, 97140) to bill since each unit was performed for the same amount of time and only one unit is allowed.”; “The above schedule of times is intended to provide assistance in rounding time into 15-minute increments.”; “It does not imply that any minute until the eighth should be excluded from the total count. The total minutes of active treatment counted for all 15 minute timed codes includes all direct treatment time for the timed codes. Total treatment minutes - including minutes spent providing services represented by untimed codes - are also documented.”; “The table below no longer contains a column noting whether a code is “timed” or “untimed” as this notation is not relevant to the number of units allowed per code on claims for the listed therapy services.”.
2. American Physical Therapy Association. Coding for Timed Codes (public practice page, undated). Checked October 25, 2026.
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   “APTA recommends billing be consistent to all payers. However, there is a distinct difference between Medicare’s 8-minute rule and the "passing the midpoint" standard in the Current Procedural Terminology (CPT) manual.”; “The American Medical Association (AMA) publishes the Current Procedural Terminology (CPT) Manual each year.”; “the "Time" guidelines provide instructions for reporting timed services and specify that the midpoint of a time interval must be exceeded before a timed unit may be billed.”; “The CPT manual guidelines do not indicate a requirement to add total minutes to determine how many units can be billed, meaning a therapist could bill 1 unit of service every time the midpoint is passed for that unit of service.”; “It is critical to review payer policy to determine whether the payer follows the Medicare 8-minute rule or whether a provider may bill a unit every time the mid-point is passed.”; “If your contract with a payer states, for example, that additional units may be billed after five minutes of services, that contract would take precedent over the standards outlined above.”.
3. American Speech-Language-Hearing Association. Understanding Timed and Untimed CPT Codes (coding guidance). Checked October 25, 2026.
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   “A timed code includes a specific time designation, such as “per 15 minutes,” “initial 30 minutes,” or “first hour.””; “An untimed code does not include a specific time designation and is generally reported as a single unit, regardless of the length of the encounter.”; “Untimed CPT codes are generally reported once per date of service, regardless of session length.”; “Although they may produce the same result in some situations, they are separate methodologies and should not be used interchangeably. Other payers may follow Medicare’s rule, apply the CPT midpoint rule, or establish their own requirements.”; “Under this rule, a unit of time is reached once more than half of the reportable time stated in the code descriptor has elapsed.”; “0–7 minutes generally would not support one unit; 8–22 minutes may support one unit; and 23–37 minutes may support two units.”; “At least 8 minutes of qualifying direct treatment must be provided before one 15-minute unit may be reported.”; “Additional units are determined based on the total qualifying timed treatment minutes provided during the encounter.”; “Medicare’s 8-minute rule only applies to 15-minute timed codes.”; “For example, Medicare requires caregiver training services reported with CPT codes 97550 and 97551 to be provided face-to-face with the caregiver, without the patient present, for the full time specified in the descriptor. However, other payers may still follow the established CPT midpoint rule for the same codes.”; “Because 97129 and 97130 are timed codes and 92526 is an untimed code”; “The same time period cannot be counted toward more than one timed CPT code.”; “start and stop times when required by the payer, facility, or organizational policy”.
4. Centers for Medicare & Medicaid Services. Medicare Benefit Policy Manual, Chapter 15, Covered Medical and Other Health Services (Rev. 13889, issued July 30, 2026; §220.3, Documentation Requirements for Therapy Services, parts A and E; §230, part A, Group Therapy Services). Checked October 25, 2026.
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   “To be payable, the medical record and the information on the claim form must consistently and accurately report covered therapy services, as documented in the medical record.”; “State or local laws and policies, or the policies or professional guidelines of the relevant profession, the practice, or the facility may be more stringent.”; “Documentation is required for every treatment day, and every therapy service.”; “Documentation of each treatment shall include the following required elements:”; “Identification of each specific intervention/modality provided and billed, for both timed and untimed codes, in language that can be compared with the billing on the claim to verify correct coding. Record each service provided that is represented by a timed code, regardless of whether or not it is billed, because the unbilled timed services may impact the billing;”; “Total timed code treatment minutes and total treatment time in minutes. Total treatment time includes the minutes for timed code treatment and untimed code treatment. Total treatment time does not include time for services that are not billable (e.g., rest periods).”; “The amount of time for each specific intervention/modality provided to the patient may also be recorded voluntarily, but contractors shall not require it, as it is indicated in the billing. The billing and the total timed code treatment minutes must be consistent.”; “Signature and professional identification of the qualified professional who furnished or supervised the services and a list of each person who contributed to that treatment”; “provided simultaneously to two or more individuals by a practitioner as group therapy services (97150). The individuals can be, but need not be performing the same activity. The physician or therapist involved in group therapy services must be in constant attendance, but one-on-one patient contact is not required.”.
5. Centers for Medicare & Medicaid Services. Billing Examples Using CQ/CO Modifiers for Services Furnished In Whole or In Part by PTAs and OTAs (page last modified February 26, 2026; its Examples A to G use 15-minute codes 97110, 97140, 97530 and 97535). Checked October 25, 2026.
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   “In the below examples (except Examples #H and #I for group therapy and RTM services, respectively) all services are for those therapy HCPCS/CPT codes that are described by 15-minute increments).”; “Services furnished by the PT together with the PTA or by the OT together with the OTA are considered to be performed by the PT/OT.”; “When a PT, PTA, OT, or OTA provides at least 15 minutes and less than 30 minutes of a service on a single treatment day, assign 1 unit; when multiples of 15 minutes are furnished, e.g., 30 minutes (assign 2 units) and 45 minutes (assign 3 units), etc. This needs to be the first step whenever it is applicable to the billing scenario.”; “When any of these services, i.e., full 15 minute increments, are provided by PTAs/OTAs, the CQ/CO modifiers apply.”; “the PT/OT meets the Medicare billing requirements for the 15-minute timed service without the minutes furnished by the PTA/OTA by providing more than the 15-minute midpoint (that is, 8 minutes or more, which is also known as the “8-minute rule”).”; “Bill for the service that took the most time. That is, assign the CQ/CO modifier to the service provided by the PTA/OTA when the time he/she spent is greater than the time spent by the PT/OT performing the different service.”; “The de minimis policy is applicable when the PT and the PTA or the OT and the OTA each independently provide minutes of the same untimed service, including: supervised modalities, evaluations and re-evaluations, group therapy, and certain RTM codes”; “1 unit is billed for all untimed codes including evaluations, reevaluations, supervised modalities, group therapy, and 2 RTM codes (98975 and 98980)”.
6. American Speech-Language-Hearing Association. Medicare Coding Rules for SLP Services (Designation of Time; CPT Codes & Special Medicare Rules for SLPs). Checked October 25, 2026.
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   “Most CPT/HCPCS codes reported by speech-language pathologists are untimed and do not include time designations in the code descriptor. An untimed code is billed once per day, regardless of the time spent providing the service.”; for 96105, “This is a timed code for each hour of testing.”; for 96125, “This is a timed code for each hour of standardized testing.”; for 97550 and 97551, “Medicare requires the CTS services to be provided for the full time to report this code.”.
7. American Speech-Language-Hearing Association. Background on Treatment Codes Replacing 92507 (coding guidance). “CPT code 92508 will remain available as a stand-alone, untimed code for group treatment of two or more individuals”; “One broad, untimed code no longer provides the level of specificity expected under current CPT coding standards.”. Checked October 25, 2026.
8. Centers for Medicare & Medicaid Services. Therapy Services (page last modified March 10, 2026). Checked October 25, 2026.
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   “Medicare applies a MPPR to the practice expense component of certain “always therapy” services.”; “Since April 1, 2013, the MPPR rate is 50 percent for both practitioner/office and institutional settings. It applies to the second and subsequent therapy services provided to a patient on the same day.”; “Payment for these services is at 85 percent of the otherwise applicable PFS payment amount/rate for the service, effective January 1, 2022.”; “portions of a service furnished by the PTA/OTA independent of the physical therapist/ occupational therapist (PT/OT), as applicable, that do not exceed 10 percent of the total service are not subject to the payment reduction”; “Portions of services provided by the PTA/OTA together with the PT/OT are counted as services provided by the PT or OT.”; “In cases where there is one final 15-minute unit left to bill, the “8-minute rule” rule is applied when the PT/OT furnishes 8 or more minutes (the Medicare billing requirement for that final 15-minute service unit)”; “that final unit is billed without the CQ/CO modifier because the PT/OT provided enough minutes on their own (more than half) to report the service.”; “When there are two units of the same service remaining to be billed, and the PT/OT and the PTA/OTA each furnish between 9 and 14 minutes of a 15-minute timed service where the total time of therapy services furnished in combination by the PTA/OTA and PT/OT is at least 23 but no more than 28 minutes, one unit of the service is billed with the CQ/CO modifier (for the unit furnished by the PTA/OTA) and one unit is billed without it (for the unit furnished by the PT/OT).”.
9. 42 CFR. §410.60, Outpatient physical therapy services: Conditions (text as published in the eCFR, issue of October 13, 2026). (a)(4)(iii)(B), (a)(4)(iv) and (c)(2). Checked October 25, 2026.
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   “furnishes a portion of a service, or in the case of a 15-minute (or other time interval) timed code, a portion of a unit of service separately from the part furnished by the physical therapist such that the minutes for that portion of a service (or unit of a service) furnished by the physical therapist assistant exceed 10 percent of the total minutes for that service (or unit of a service).”; “does not apply when determining whether the prescribed modifier applies to the last 15-minute unit of a service billed for a patient on a treatment day, when the physical therapist provides more than the midpoint of a 15-minute timed code, that is, 8 or more minutes, regardless of any minutes for the same service furnished by the physical therapist assistant.”; “Physical therapy services may be performed by a physical therapist assistant under the general supervision of the physical therapist in private practice; services performed by an unenrolled physical therapist must be under the direct supervision of the physical therapist.”.
10. 42 CFR. §410.59, Outpatient occupational therapy services: Conditions (text as published in the eCFR, issue of October 13, 2026). (a)(4)(ii), (a)(4)(iv) and (c)(2). Checked October 25, 2026.
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    “claims for such services that include the modifier and for which payment is made under sections 1848 or 1834(k) of the Act are paid an amount equal to 85 percent of the amount of payment otherwise applicable for the service.”; “does not apply when determining whether the prescribed modifier applies to the last 15-minute unit of a service billed for a patient on a treatment day when the occupational therapist provides more than the midpoint of a 15-minute timed code, that is, 8 or more minutes, regardless of any minutes for the same service furnished by the occupational therapy assistant.”; “Occupational therapy services may be performed by an occupational therapy assistant under the general supervision of the occupational therapist in private practice; services performed by an unenrolled occupational therapist must be under the direct supervision of the occupational therapist.”.
11. Centers for Medicare & Medicaid Services. Medicare Claims Processing Manual, Chapter 5, Part B Outpatient Rehabilitation and CORF/OPT Services (§20, HCPCS Coding Requirement, Rev. 1850, effective January 1, 2010). Checked October 25, 2026.
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    “This requirement does not apply to outpatient rehabilitation services provided by:”; “Critical access hospitals, which are paid on a cost basis, not MPFS;”; “RHCs, and FQHCs for which therapy is included in the all-inclusive rate;”; “The following “providers of services” must bill the A/B MAC (A) for outpatient rehabilitation services using HCPCS codes:”; “Hospitals (to outpatients and inpatients who are not in a covered Part A stay);”; “The following practitioners must bill the A/B MAC (B) for outpatient rehabilitation therapy services using HCPCS/CPT codes:”; “Physical therapists in private practice (PTPPs),”; “Occupational therapists in private practice (OTPPs),”; “Speech-language pathologists in private practice (SLPPs),”; “Note 1. The requirements for hospitals and SNFs apply to inpatient Part B and outpatient services only. Inpatient Part A services are bundled into the respective prospective payment system payment; no separate payment is made.”; “Note 2. For HHAs, HCPCS/CPT coding for outpatient rehabilitation services is required only when the HHA provides such service to individuals that are not homebound and, therefore, not under a home health plan of care.”.
12. Centers for Medicare & Medicaid Services. Annual Therapy Update (page last modified March 4, 2026), with its 2026 Therapy Code List and Dispositions (ZIP), disposition 11. Checked October 25, 2026.
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    “The files on this web page contain the list of codes indicating whether they are sometimes or always therapy services.”; “the initial 30 minutes of G0541 and 97550 can only be billed if the full 30 minutes is provided and each additional 15 minutes of G0542 and 97551 can only be billed if the full 15 minutes is provided for each 15-minute unit.”; “The group codes G0543 and 97552 are not timed”.
13. Centers for Medicare & Medicaid Services. Medicare Claims Processing Manual, Chapter 5, Part B Outpatient Rehabilitation and CORF/OPT Services (§20.1, Discipline Specific Outpatient Rehabilitation Modifiers, Rev. 11129, effective January 1, 2022). Checked October 25, 2026.
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    “The claim must include one of the following modifiers to distinguish the discipline of the plan of care under which the service is delivered:”; “GN Services delivered under an outpatient speech-language pathology plan of care;”; “GO Services delivered under an outpatient occupational therapy plan of care; or,”; “GP Services delivered under an outpatient physical therapy plan of care.”; “CMS has established two modifiers, CQ and CO, for services furnished in whole or in part by physical therapist assistants (PTAs) and occupational therapy assistants (OTAs).”; “The CQ modifier must be paired to the GP therapy modifier and the CO modifier with the GO therapy modifier.”; “For dates of service, on and after January 1, 2022, claims billed with a CQ or CO modifier to indicate the services were furnished in whole or in part by a PTA or OTA are paid at an amount equal to 85 percent of the otherwise applicable Part B payment that’s based on the MPFS. The 15 percent reduction is taken last, e.g., after the MPPR (and other reductions where applicable) and right before sequestration.”.
14. Centers for Medicare & Medicaid Services. National Correct Coding Initiative Policy Manual for Medicare Services, Chapter 11 (2026 manual, revision date January 1, 2026; section P, Physical Medicine and Rehabilitation, item 2). Checked October 25, 2026.
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    “With one exception, providers/suppliers shall not report more than one physical medicine and rehabilitation therapy service for the same fifteen-minute time period. (The only exception involves a “supervised modality” defined by CPT codes 97010-97028, which may be reported for the same fifteen-minute time period as other therapy services.)”; “Some NCCI PTP edits pair a “timed” CPT code with another “timed” CPT code or a non-timed CPT code. These edits may be bypassed with modifier 59 or XU if the 2 procedures of a code pair edit are performed in different timed intervals even if sequential during the same patient encounter.”; “Physicians are expected to code correctly even in the absence of NCCI PTP edits.”.
15. Centers for Medicare & Medicaid Services. Medicare Claims Processing Manual, Chapter 5, Part B Outpatient Rehabilitation and CORF/OPT Services (§20.3, Determining What Time Counts Towards 15-Minute Timed Codes, Rev. 1; and §20.4, Coding Guidance for Certain CPT Codes, Rev. 3475). Checked October 25, 2026.
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    “Pre- and post-delivery services are not to be counted in determining the treatment service time.”; “the time counted as “intra-service care” begins when the therapist or physician (or an assistant under the supervision of a physician or therapist) is directly working with the patient to deliver treatment services.”; “The patient should already be in the treatment area (e.g., on the treatment table or mat or in the gym) and prepared to begin treatment.”; “The time counted is the time the patient is treated.”; “each 15 minutes the patient is being treated can count as only one unit of code 97116.”; “The time the patient spends not being treated because of the need for toileting or resting should not be billed. In addition, the time spent waiting to use a piece of equipment or for other treatment to begin is not considered treatment time.”; “Providers report code 96105, assessment of aphasia with interpretation and report in 1-hour units.”; “The interval for code 97545 is 2 hours and for code 97546, 1 hour.”; “The expectation is that the entire time period specified in the codes 97545 or 97546 would be the treatment period”.
16. UnitedHealthcare. Physical Medicine & Rehabilitation: Maximum Combined Frequency per Day Policy, Professional (Commercial and Individual Exchange reimbursement policy 2026R0101A; history entry April 1, 2026; its code table lists 97032 to 97036, 97110, 97112, 97113, 97116, 97124, 97129, 97130, 97140, 97530, 97533, 97535, 97537, 97542, 97750, 97755, 97760, 97761, 97763, G0237, G0238 and S8948). Checked October 25, 2026.
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    “This policy describes reimbursement for Physical Medicine and Rehabilitation Therapy CPT/HCPCS codes containing a time element.”; “These services are referred to as “timed codes” within the policy.”; “Note: In alignment with the Centers for Medicare and Medicaid Services (CMS), at least eight minutes of therapy services must be performed to meet the minimum time qualification to bill one 15 minute unit.”; “up to a maximum of four timed codes (equivalent to one hour of therapy) per date of service, provided by the Same Specialty Physician or Other Qualified Health Care Professional.”; “This policy does not apply to services provided in the home or in a comprehensive inpatient or outpatient rehabilitation facility (CMS Place of Service designations 12, 61 or 62).”; “This policy does not apply to UnitedHealthcare® Oxford.”; “UnitedHealthcare will consider additional reimbursement upon Reconsideration Request.”.
17. Washington State Health Care Authority. Washington Apple Health (Medicaid) Outpatient Rehabilitation Billing Guide (July 10, 2026). Checked October 25, 2026.
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    “Each 15 minutes of a timed CPT® code equals one unit.”; “Each nontimed CPT® code equals one unit regardless of how long the procedure takes.”; “The client’s medical record must include detailed documentation for each timed CPT® code, specifying the date of service with the therapy modality start and end times.”; “For eligible clients age 20 years and younger, the Health Care Authority covers unlimited outpatient rehabilitation, with the exception of clients age 19 through 20 receiving Medical Care Services (MCS).”; “The following are the short-term benefit limits for outpatient rehabilitation for clients age 21 and older, and clients age 19 through 20 receiving MCS.”; “These benefit limits are per client, per calendar year regardless of setting.”; “Physical therapy 24 units (equals approximately 6 hours)”; “Speech therapy 6 units (equals a total of 6 untimed visits)”; “CPT® codes and descriptions only are copyright 2025 American Medical Association.”.
18. Noridian Healthcare Solutions, Medicare Administrative Contractor for Jurisdiction F Part B (Alaska, Arizona, Idaho, Montana, North Dakota, Oregon, South Dakota, Utah, Washington, Wyoming). Rehabilitation Delivery Methods (JF Part B billing article, last updated July 11, 2025). Checked October 25, 2026.
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    “It is not appropriate to count minutes for skilled services that are overseen and/or provided by a therapy aide even though the aide may be supervised by a qualified clinician.”; “It is not appropriate to count individual therapy minutes when treatment is provided to more than one patient at the same time.”; “Since time-based code units are determined by total minutes of service, the end result would be one billable unit of time-based service.”; “Both clinicians cannot each bill separately for the same or different service provided at the same time to the same patient.”; “A PT and an OT work together for 30 minutes with one patient on transfer activities. The PT and OT could each bill 15 minutes. Alternatively, the total 30 minutes could be billed by either the PT or the OT, but not both.”; “hospital-based outpatient therapy clinic (HTC), outpatient rehabilitation facility (ORF), comprehensive outpatient rehabilitation facility (CORF) and independent therapy clinic (ITC)”; “Inpatient hospital, LTC, HTC, ORF, CORF, ITC - Patients cannot be treated concurrently: A therapist may treat only one patient at a time.”; “When both Current Procedural Terminology (CPT) and Medicare requirements are met, for individual and group therapy services provided to the same patient on the same day, then both services may be billed.”; “During a 30-minute group session, a therapist works with two patients and divides his/her time between the two patients. The therapist will appropriately bill each patient one unit of the untimed group therapy code.”; “Documentation must clearly distinguish the group therapy activity/untimed minutes from the individual therapy activity/time-based minutes. Modifier 59 may be used as appropriate when all requirements are met.”.
19. American Speech-Language-Hearing Association. Speech-Language Pathology Treatment Codes Replacing 92507 (coding guidance). Checked October 25, 2026.
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    “CPT code 92507 remains in effect through December 31, 2026. The new codes take effect January 1, 2027.”; “should verify implementation requirements with each payer, as they may vary.”; “Final Medicare values will be established in the CY 2027 MPFS final rule.”; “Other payers may decide if and when to implement the new codes into their fee schedules.”.
20. American Speech-Language-Hearing Association. Treatment Code Family Replacing 92507 (coding guidance; Understanding the Time-Based Structure). Checked October 25, 2026.
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    “The base code describes the initial 30 minutes, and the associated add-on code describes each additional 15 minutes.”; “Under the general CPT midpoint convention, clinicians may typically report the base code after they provide 16 minutes of the described service.”; “However, CPT instructions, CMS rules, and payer policies may establish different requirements.”.
21. Noridian Healthcare Solutions, Medicare Administrative Contractor for Jurisdiction F Part B. Common Errors (Comprehensive Error Rate Testing findings, Outpatient Therapy; last updated July 30, 2025). Checked October 25, 2026.
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    “Services provided in an Outpatient Therapy specialty, such as E/Ms, CPTs 97110, 97035, 97140 and HCPCS G0283 were not supported due to insufficient documentation and incorrect coding.”; “Therapy - Documentation supports UOS change”.
22. DrSensory. DrSensory for therapists (the For Therapists hub). Checked October 24, 2026.
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    “DrSensory is a directory families use free to find occupational therapy, physical therapy and speech therapy clinics”; “across all 50 states and Washington, DC”; “Every clinic keeps a basic listing at no cost.”; “The directory lists clinics rather than individual therapists, so one listing covers a whole practice at one address.”; “Claiming is free and has three steps: find your listing, confirm your email with a six-digit code, choose a password.”; “There is no contract, and nothing is charged while you claim.”; “Therapy and developmental resources for children and adults, plus a directory of providers across the United States.”.
23. DrSensory. Therapy Clinic Directory Pricing (the pricing page and its frequently asked questions). Checked October 24, 2026.
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    “Outpatient physical therapy, occupational therapy, and speech-language pathology clinics. The directory lists clinics rather than individual therapists, so one listing covers your whole practice. Inpatient rehabilitation facilities and chiropractic practices are not listed.”; “$29.99 a month or $349.99 a year for your first location, and $9.99 a month or $99.99 a year for each additional location”; “Claiming your listing is free.”; “A description in your own words”; “We do not verify clinical quality”; “A listing means a practice appears in the directory. It is not a recommendation”; “Families never pay to search it or to contact a clinic”; “When a family writes from your profile, the address you gave for family inquiries is told that a message is waiting; you read it signed in, because what a parent writes about their child is health information, and you reply from your own address.”.

Medical disclaimer. This page is for general educational purposes and does not constitute medical advice, diagnosis, or treatment. It is general guidance on running a therapy practice, not legal, compliance, billing or financial advice. Its visits and minutes are hypothetical examples, not DrSensory data.