Reporting Therapy Units Correctly

on Tuesday, 23 April 2019. All News Items | Outpatient Services | Billing

A Timely Subject

April is National Occupational Therapy Month. The American Occupational Therapy Association (AOTA) states on their website, “Occupational therapy practitioners enable people of all ages to live life to its fullest by helping them promote health, and prevent—or live better with—injury, illness, or disability.” In honor of OT month (and also with a nod to physical therapists and speech language pathologists) today’s article will address the issue of the correct reporting of therapy units.

Although the reporting of timed therapy codes would seem to be more difficult than untimed codes, this April’s Medicare Quarterly Provider Compliance Newsletter addresses errors identified by the Recovery Auditors for the reporting of untimed therapy codes. To cover all our bases, let’s review both.

A number of CPT codes, such as constant attendance modalities and most therapeutic procedures, specify a time frame of 15 minutes as the direct one-on-one time spent providing the therapy service to the patient. These are referred to as “timed” therapy procedure codes.

When a therapy service is not defined by a specific timeframe, it is an “untimed” therapy procedure (CPT or HCPCS) code. Untimed codes are billed with a unit of one (1) per date of service. The unit for untimed codes is one regardless of how long the evaluation or service took. Providers should enter a 1 in the ‘units bill’ column per date of service. Below is a table of the untimed therapy codes. There may be exceptions to a unit of one if a patient has more than one encounter on the same day.

 SLP Services PT Evaluations
92507 Speech treatment, individual 97001 PT Evaluation (prior to 2017)
92508 Speech treatment, group 97002 PT Re-evaluation (prior to 2017)
92521 Evaluation, speech fluency 97161 PT Eval, low complexity
92522 Evaluation, sound production 97162 PT Eval, moderate complexity
92523 Evaluation, language comprehension 97163 PT Eval, high complexity
92524 Voice analysis 97164 PT Re-evaluation
92526 Swallowing treatment    
92597 Evaluation, voice prosthetic    
92609 Therapeutic services speech device    
 Modalities OT Evaluations
97012 Mechanical traction 97003 OT Evaluation (prior to 2017)
97016 Vasopneumatic devices 97004 OT Re-evaluation (prior to 2017)
97018 Paraffin bath 97165 OT Eval, low complexity
97022 Whirlpool 97166 OT Eval, moderate complexity
97024 Diathermy 97167 OT Eval, high complexity
97028 Ultraviolet 97168 OT Re-evaluation
G0281 Unattended E-stim, ulcers (wound care)    
G0283 Unattended E-stim    
G0329 Electromagnetic therapy, ulcers (wound care)    

Timed therapy codes include in their CPT description the time frame of “each 15 minutes” and units are calculated based on the total time of all “timed” code services. Per the Medicare Claims Processing Manual, chapter 5, section 20.2, “Providers report these “timed” procedure codes for services delivered on any single calendar day using CPT codes and the appropriate number of 15 minute units of service.” The total number of units billed for “timed” services are based on the total time of the “timed” services according to the following chart. If more than one “timed” service is provided, add the minutes of all “timed” services together and get the total number of “timed” units to be billed. These are then divided appropriately among the various “timed” services provided. Although Medicare requires providers to report the total treatment time (timed and untimed services), do not add the minutes of “untimed” codes when calculating the units of “timed” services.

Units Number of 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

Pattern continues…

Do not report any units if total minutes of timed therapy services is less than 8 minutes


See Section 20.2 of Chapter 5 of the Claims Processing Manual for examples of the billing of timed codes. Here is a straight forward example from the Manual:

“Example 1 –

  • 24 minutes of neuromuscular reeducation, code 97112,
  • 23 minutes of therapeutic exercise, code 97110,
  • Total timed code treatment time was 47 minutes.

See the chart above. The 47 minutes falls within the range for 3 units = 38 to 52 minutes.

Appropriate billing for 47 minutes is only 3 timed units. Each of the codes is performed for more than 15 minutes, so each shall be billed for at least 1 unit. The correct coding is 2 units of code 97112 and one unit of code 97110, assigning more timed units to the service that took the most time.”

Other examples in the Manual address trickier situations, such as the division of an odd number of units if both services are the same length, division of units if the number of different services exceeds the number of units, and the counting of services lasting less than 8 minutes.

One of the most common time errors I see when reviewing therapy records is the inclusion of the time of “untimed” codes in the time used to calculate code minutes. Remember, untimed codes are billed with 1 unit per day of service and “untimed” code minutes do not affect the overall units of codes.

  • For example, a patient receives 25 minutes of therapeutic exercise (CPT 97110) and 10 minutes of unattended e-stim (HCPCS G0283).
  • Do not add the 10 minutes of unattended e-stim to the 25 minutes of ther ex for a total of 35 minutes, limiting your total units to 2.
  • In this situation, 35 minutes is the total treatment time, but the total “timed” code minutes is 25 for 2 units of ther ex (97110). The unattended e-stim, as an untimed code, is reported with units of 1.

Separate your “timed” and “untimed” minutes when determining units – untimed codes = units of one (1); timed codes = units based on total minutes of “timed” codes only.

Therapy providers should know their “timed” versus “untimed” code and keep them separate for calculating units. Again, we at MMP wish a timely Happy OT Month to all the dedicated and hard-working Occupational Therapists who help their patients “live life to its fullest.”

Article by Debbie Rubio

Debbie Rubio, BS, MT (ASCP), is the Manager of Regulatory Affairs and Compliance at Medical Management Plus, Inc.  Debbie has over twenty-seven years of experience in healthcare including nine years as the Clinical Compliance Coordinator at a large multi-facility health system.  In her current position, Debbie monitors, interprets and communicates current and upcoming regulatory and compliance issues as they relate to specific entities concerning Medicare and other payers.  You may contact Debbie at This email address is being protected from spambots. You need JavaScript enabled to view it..

This material was compiled to share information.  MMP, Inc. is not offering legal advice.  Every reasonable effort has been taken to ensure the information is accurate and useful.

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