The exercise itself does not determine the code. What a patient physically does during a session is rarely the deciding factor in whether 97110 is correct. A patient performing a sit-to-stand can be therapeutic exercise, neuromuscular reeducation, or therapeutic activities depending entirely on why the therapist selected it and what the note says it addressed.
That single reality explains most 97110 denials that have nothing to do with time or modifiers. Payers are not questioning whether treatment happened. They are questioning whether what happened fits the definition of therapeutic exercise, and whether it required a therapist at all.
This guide covers what actually qualifies under 97110, how the same intervention maps to different codes, what makes exercise skilled rather than routine, and how maintenance therapy fits into the picture.
The Four Parameters That Define Therapeutic Exercise
CPT 97110 describes therapeutic exercises to develop strength and endurance, range of motion, and flexibility. Those four parameters are the entire scope of the code.
| Parameter | What It Addresses | Typical Interventions | What the Note Should Show |
|---|---|---|---|
| Strength | Force production in weak muscle groups | Progressive resistive exercise, resistance bands, weighted work | Muscle group, resistance level, sets and reps |
| Endurance | Sustained capacity over time | Treadmill, cycle ergometer, sustained repetition work | Duration, intensity, tolerance response |
| Range of motion | Joint mobility limits | Active and active-assisted ROM, pulleys, wand exercises | Joint, degrees or measurable limits, progress |
| Flexibility | Soft tissue extensibility | Sustained static stretching, contract-relax techniques | Muscle or tissue targeted, hold time, response |
If the documented purpose of an intervention is not one of those four, 97110 is likely the wrong code even when the activity looks like exercise. This is the single most useful filter to apply before selecting the code.
Also Read: 97110 CPT Code: Complete Physical Therapy Billing Guide
Same Exercise, Different Code
This is where documentation earns its keep. Identical physical activity routes to different codes based on stated clinical intent.
| Intervention | Documented Purpose | Correct Code |
|---|---|---|
| Single leg stance | Quadriceps and hip strengthening | 97110 |
| Single leg stance | Proprioceptive retraining and postural control | 97112 |
| Sit to stand repetitions | Lower extremity strength building | 97110 |
| Sit to stand repetitions | Functional transfer training for home safety | 97530 |
| Treadmill walking | Cardiovascular endurance conditioning | 97110 |
| Treadmill walking | Gait pattern correction and ambulation mechanics | 97116 |
| Shoulder pulley exercise | Restoring shoulder range of motion | 97110 |
| Lifting and carrying a weighted box | Simulating a work or home functional demand | 97530 |
A reviewer reading two codes on the same claim needs to see two different clinical purposes in the note. When both entries describe lower extremity strengthening, the second code will not survive review regardless of which modifier was appended.
The Skilled Service Test
Beyond code selection sits a more fundamental question: did this require a therapist?
Medicare covers therapy when the service requires the skills of a qualified therapist and cannot be safely and effectively performed by the patient alone or by an unskilled caregiver. Exercise a patient could reasonably do from a printed home program is generally not billable as a skilled service, no matter how appropriate it is clinically.
What establishes skill in the record:
- Assessment and adjustment during the session, such as modifying resistance based on observed compensation.
- Clinical decision-making about progression, regression, or exercise selection.
- Cueing and correction for form, alignment, or technique.
- Safety monitoring for a patient whose condition makes independent performance unsafe.
- Response to an adverse or unexpected reaction during treatment.
Documentation reading “patient completed therapeutic exercise for 20 minutes” establishes that time passed. Documentation describing a resistance increase based on observed movement quality, with verbal and tactile cueing for hip control, establishes that a therapist was necessary. Only the second version supports the claim.
Direct One-on-One Contact: What Counts and What Does Not
97110 requires direct one-on-one contact with the qualified provider. That requirement is more restrictive than practices sometimes treat it.
Time that counts:
- The therapist is engaged with this patient, providing skilled intervention.
Time that does not count:
- The patient performs exercises independently while the therapist works elsewhere.
- The therapist supervises several patients exercising simultaneously.
- The patient rests between sets without skilled interaction.
- Setup, equipment adjustment, and documentation time.
When a therapist is providing simultaneous treatment to two or more patients, the appropriate code is 97150 for group therapeutic procedures, regardless of whether each patient is doing a different exercise. Billing 97110 for supervised group work is a recognized compliance exposure, not a gray area.
Maintenance Therapy and the Improvement Question
A persistent myth holds that Medicare only covers therapy when the patient is expected to improve. That belief has been formally incorrect since 2013.
The Jimmo v. Sebelius settlement, approved in January 2013, ended the informal improvement standard. CMS updated its policy manuals accordingly and has continued issuing clarifying guidance, most recently a set of frequently asked questions released in March 2026.
The coverage test is whether skilled care is needed, not whether function will improve. Therapy can be covered when it is necessary to maintain a patient’s current condition, or to prevent or slow further decline. This applies regardless of the underlying diagnosis and is not limited to chronic or progressive conditions.
What the settlement did not do is lower the skilled service bar. Maintenance therapy is covered when the skills of a therapist are required for safe and effective performance, and the program cannot be carried out by the patient or an unskilled caregiver. If the maintenance program can be handed off safely, the skilled coverage ends.
For documentation, this means a note on a maintenance patient needs to articulate why a therapist remains necessary rather than defaulting to progress language that the clinical picture does not support. Writing manufactured improvement into a maintenance chart creates a different problem than the one it was meant to solve.
Therapeutic Exercise Is Not a Modality
Modalities and therapeutic procedures are separate categories, and their time does not blend.
Supervised modalities such as hot and cold packs, mechanical traction, unattended electrical stimulation, and paraffin do not require constant attendance and are not timed codes. Their minutes contribute nothing to the timed total. Hot and cold pack application in particular is bundled under Medicare and is not separately payable.
Constant attendance modalities such as manual electrical stimulation, iontophoresis, contrast baths, and ultrasound are timed codes billed in15-minutee units, and their minutes do count toward the timed total for unit calculation.
Counting supervised modality time toward 97110 units is a straightforward overbilling error, and it is one that shows up quickly in a chart review because the modality is documented separately.
When 97110 Is Not the Right Code
Several codes describe exercise-based interventions but sit outside 97110:
- Aquatic therapy with therapeutic exercises has its own code, 97113. Therapeutic exercise performed in a pool is billed there, not under 97110.
- Group therapeutic procedures fall under 97150 when the therapist treats two or more patients simultaneously.
- Work conditioning and work hardening programs use their own codes, billed in different time increments than the standard 15-minute unit.
- Self-care and home management training, including activities of daily living and adaptive technique instruction, belongs under 97535.
- Community and work reintegration training belongs under 97537.
Selecting 97110 because it is familiar, when a more specific code exists, understates the service and can create pattern issues across a practice’s claims.
Also Read: Physical Therapy Billing Units Comprehensive Guide
Documentation That Establishes Skilled Therapeutic Exercise
A defensible 97110 note consistently captures:
- Which specific exercises were performed, with sets, repetitions, resistance, or duration.
- Which of the four parameters the exercise addressed.
- The measurable impairment being treated, tied to an objective deficit rather than a general complaint.
- The skilled decision made during the session, such as a progression, modification, or safety intervention.
- Patient response, including tolerance, compensation patterns, or adverse reaction.
- Connection to a goal in the plan of care.
- Treatment minutes recorded for 97110 specifically, separate from other timed services.
The parameter statement is worth emphasizing. A note that names the exercise but never states whether it addressed strength, endurance, range of motion, or flexibility leaves the reviewer to infer the code’s justification.
Common Pitfalls With Therapeutic Exercise Claims
At Zee Medical Billing LLC, we often see the same patterns surface in therapy denials and audit findings:
- Documenting the exercise performed without stating which parameter it addressed.
- Billing 97110 for interventions whose documented purpose fits 97112, 97116, or 97530.
- Counting independent exercise or rest time toward one-on-one units.
- Billing 97110 rather than 97150 when multiple patients were treated simultaneously.
- Notes that establish time but never establish skill.
- Assuming maintenance therapy is not covered, or writing false improvement language to avoid the issue.
- Including supervised modality minutes in the timed total.
- Using 97110 for aquatic therapeutic exercise instead of 97113.
- Repeating identical exercise documentation visit after visit with no progression, modification, or clinical reasoning.
That last one deserves attention. Copy-forward documentation is efficient and is also the clearest possible signal to a reviewer that no skilled decision-making occurred, even when it did.
FAQs
What exercises qualify as therapeutic exercise under 97110?
Any exercise whose documented purpose is developing strength, endurance, range of motion, or flexibility can qualify. Common examples include progressive resistive exercise, resistance band work, treadmill or cycle work for endurance, active and active-assisted range of motion, and sustained stretching. The activity itself is less important than the documented clinical parameter it addresses. If the purpose is balance, motor control, or coordination, the intervention belongs under 97112. If it is a functional task combining several parameters, it belongs under 97530.
Can 97110 be billed while the patient exercises independently?
No. 97110 requires direct one-on-one contact with the qualified provider. Time during which a patient exercises without the therapist actively engaged does not count toward billable units, even if the therapist assigned the exercise and remains in the room. If the therapist is treating two or more patients simultaneously, the appropriate code is 97150 for group therapeutic procedures. Billing individual therapy codes for supervised group exercise is a recognized compliance risk rather than an interpretation question.
Can 97110 be billed for maintenance therapy?
Yes, when the skilled service standard is met. The Jimmo v. Sebelius settlement ended Medicare’s informal improvement standard, and CMS has confirmed that coverage depends on whether skilled care is required, not on whether the patient is expected to improve. Therapy to maintain current function or to slow decline is covered when the therapist’s skills are necessary for safe and effective performance. The key documentation requirement is explaining why a therapist remains necessary, rather than defaulting to progress language the clinical picture does not support.
Can occupational therapists bill 97110?
Yes. CPT 97110 is not restricted to physical therapy and may be reported by occupational therapists when the intervention fits the code definition and falls within their scope of practice. The difference on the claim is the discipline modifier. Occupational therapy services use GO rather than GP, and speech-language pathology services use GN. The documentation requirements are identical regardless of discipline, and the same skilled service standard applies.
What is the difference between 97110 and aquatic therapy?
Aquatic therapy with therapeutic exercises has its own code, 97113, which covers therapeutic exercise performed in a pool or aquatic environment. When the therapeutic exercise takes place in water, 97113 is the correct code rather than 97110. The distinction is the setting, not the exercise. Both are timed codes billed in 15-minute units with the same one-on-one requirement, and both require documentation showing the skilled component and the clinical parameter being addressed.
Conclusion
97110 is defined by clinical purpose, not by activity. The four parameters in the code definition are the boundary, the skilled service standard is the coverage test, and the documentation is what connects the two for anyone reviewing the claim later.
Key takeaways:
- Therapeutic exercise addresses strength, endurance, range of motion, or flexibility, and nothing else.
- The same exercise maps to different codes depending on documented intent.
- Skilled service means the therapist’s judgment was required, not just present.
- Only direct one-on-one time counts, and simultaneous treatment of multiple patients belongs under 97150.
- Maintenance therapy is covered when skilled care is needed, since improvement is not the standard.
- Supervised modality minutes never feed the timed total.
- Aquatic therapeutic exercise, work conditioning, and self-care training each have their own codes.
When the note names the exercise, names the parameter, and shows the clinical decision behind it, 97110 becomes straightforward to defend.
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