CPT 97110 Billing Guide 2025 - Therapeutic Exercise Documentation & Rates

CMS 2026 Update — CPT 97110

CY2026 guidance for CPT 97110 (Therapeutic exercise) remains consistent: document specific exercises, targeted impairments, and progress toward functional goals. CMS highlighted accurate time tracking and medical necessity as audit priorities.

What is CPT 97110?

CPT 97110 represents therapeutic exercise — a procedure involving exercises to develop strength, range of motion (ROM), and endurance.

Typical uses: Rehabilitation post-surgery, chronic pain management, and improving functional mobility.

In short: CPT 97110 = Targeted therapeutic exercise for strength, ROM, and endurance.

When to Use CPT 97110 (and When Not To)

Use 97110 for individualized therapeutic exercises aimed at improving physical function.

• Report when exercises are prescribed and monitored by a licensed therapist.
• Ensure documentation supports medical necessity and skilled intervention.

Do not use for general fitness or exercises not requiring skilled intervention.

Clinical Examples

• Post-operative knee rehabilitation → 97110
• General gym workout → Not applicable

97110 vs 97112 (Quick Comparison)

2025 Reimbursement Rates (Representative)

Documentation Guidelines (CMS & MIPS 2025 Compliant)

Thorough documentation demonstrates medical necessity, skilled care, and functional intent. Include:

1. Functional goal (e.g., “Patient will increase knee flexion by 10 degrees”).
2. Activity description — explicit tasks practiced, environment, and level of assistance.
3. Clinical rationale — why this activity addresses the patient’s deficit.
4. Time documentation — minutes per activity and total minutes (apply the 8-minute rule for units).
5. Patient response — tolerance, cues required, measurable progress.

Sample SOAP Note (De-identified)

S: Patient reports mild discomfort during exercises but is motivated to continue.
O: Patient completed 20 minutes of therapeutic exercises focusing on lower extremity strength.
A: Improved endurance noted; patient tolerated exercises well with minimal cues.
P: Continue current exercise regimen, increase resistance as tolerated.
  

Modifiers & Coding Tips

Claim tip: Ensure documentation supports the use of modifiers to avoid denials.

Common Denials & How to Prevent Them

1. Insufficient documentation — Fix: Ensure thorough documentation of medical necessity and skilled intervention.
2. Incorrect modifier usage — Fix: Use appropriate modifiers and ensure documentation supports their use.
3. Exceeding therapy caps — Fix: Monitor therapy caps and request exceptions when necessary.

Audit trigger: Frequent use of -59 modifier without clear documentation.

Region & Local Payer Notes

In California, CPT 97110 is subject to specific guidelines under Palmetto GBA. Providers should verify local MAC policies and ensure compliance with state-specific Medicaid rules.

FAQs

What qualifies as therapeutic exercise under 97110?

Therapeutic exercise includes active, repeated movements to restore strength, endurance, or range of motion. Document the exercise type, repetitions, resistance, and patient response.

How do I document units for 97110?

Record precise start/end times and minutes spent on each exercise to apply the 8-minute rule for timed codes.

Can 97110 be billed with 97530?

Yes, when services are distinct in purpose and content; document separate goals and skilled actions.

What causes denials for 97110?

Denials commonly result from vague documentation, lack of measurable goals, or incorrect unit calculation.

Is prior authorization needed for exercise therapy?

Some commercial payers require prior authorization for prolonged therapy courses; Medicare rarely does for standard outpatient PT.

How to demonstrate progress in notes?

Include objective measures and comparisons over time tying improvements to functional gains.