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We're ready and eager to meet your billing needs.
Physical therapy billing is the process of turning documented treatment into a claim, tracking the payer’s response, and following up on payment or denial. This guide walks through patient information, documentation and coding, claim submission, adjudication, and payment follow-up. Start with the workflow below, then use the linked resources for Medicare timed units, denial-code explanations, and billing costs. Looking for billing support rather than a process guide? See our physical therapy billing services and compare billing service costs.
In this guide: Billing workflow · CPT codes & timed units · Modifiers (GP, KX, CQ, 59) · Medicare enrollment & revalidation · Substitute PT billing (Q5/Q6) · MPPR, PTA rate & telehealth · Medicare documentation checklist · Diagnosis codes, filing limits & group therapy · Billing software · In-house vs. outsourced billing · Next billing resources
Physical therapy billing involves the submission of claims to insurance companies or other payers to receive payment for services provided. The process typically includes the following steps:
This initial step involves collecting accurate patient information and verifying insurance coverage. For Original Medicare, keep the eligibility response with the date of the inquiry and the requested date of service. CMS explains that HETS eligibility data is accurate only at the time of the transaction and that a 271 response is not a guarantee of payment. Direct Medicare Advantage benefit questions to the plan identified in the response, rather than assuming that Medicare Part A or Part B eligibility establishes that plan’s benefits. See CMS HETS eligibility guidance (May 2026, disclosure statement and page 2). It is crucial to ensure that patients’ insurance details are up to date and accurately recorded to avoid potential claim denials.
Match the billed services and units to the treatment record rather than relying on software suggestions alone. For Medicare outpatient therapy, CMS requires documentation of both timed-code treatment minutes and total treatment time, including timed and untimed services. Do not count untimed-service minutes toward timed-code units. See the CMS outpatient rehabilitation documentation guidance (pages 3, 6 and 7). Use our Medicare 8-minute rule calculator as a calculation aid, not a replacement for the treatment record or the applicable payer policy.
Also Read: 10 Reasons Why Your Physical Therapy Insurance Claims Will Get Denied
Before transmitting a claim, confirm the billing provider type, payer requirements and required claim format. For Medicare, CMS identifies 837P as the electronic format for health care professionals and suppliers, and 837I as the electronic format for institutional providers. The corresponding paper forms are CMS-1500 and CMS-1450 (UB-04); Medicare paper submission is subject to applicable Administrative Simplification Compliance Act (ASCA) exceptions. See CMS professional billing guidance and CMS institutional billing guidance (December 2025, page 3). Do not assume that every physical therapy claim uses the same format; confirm the applicable provider and payer instructions before submission.
The insurance company reviews the claim, verifies the information, and determines the amount of reimbursement. This process can involve various stages, including claim edits, eligibility verification, and medical necessity review.
Separate a rejected claim from a denied claim. For Original Medicare electronic claims, CMS describes front-end checks that can reject a batch or an individual claim for correction and resubmission. Later coverage and payment-policy edits can result in a rejection or a denial. Read the actual response before choosing the next step; a transmission acknowledgment is not a payment decision. See CMS: How Electronic Claims Submission Works.
Reconcile the remittance with the submitted claim. Medicare remittance advice reports adjudication and payment information, including the reason and value of adjustments. Review the claim adjustment group code, claim adjustment reason code (CARC), and any remittance advice remark code (RARC) together. See CMS remittance advice guidance and our physical therapy denial-code guide.
Choose the payer-specific follow-up. Before correcting, resubmitting or appealing, check the payer’s instructions and applicable deadline against the actual response and supporting records. Do not automatically resubmit every denied claim. Keep the claim, acknowledgment, remittance and follow-up records together; other insurance plans may use different processes.
Physical therapy claims combine untimed (service-based) codes—which bill 1 unit per date of service regardless of how long they take—and timed (15-minute) CPT codes, which require direct one-on-one contact and documented timed minutes (CMS Medicare Claims Processing Manual, Pub. 100-04, Chapter 5, Section 20.2).
| Code | Service Description | Timed or Untimed | Medicare & Payer Billing Note |
|---|---|---|---|
| 97110 | Therapeutic exercise | Timed, 15-minute units | Requires direct one-on-one contact; minutes pool toward total timed units under Medicare. |
| 97112 | Neuromuscular re-education | Timed, 15-minute units | Targets balance, coordination, posture, or proprioception; counted in timed minute total. |
| 97116 | Gait training | Timed, 15-minute units | Includes stair climbing and assistive device training; counted in timed minute total. |
| 97140 | Manual therapy techniques | Timed, 15-minute units | Joint mobilization/manipulation and manual traction; check NCCI edits when billed with other codes (CO-236). |
| 97530 | Therapeutic activities | Timed, 15-minute units | Dynamic functional activities (lifting, reaching, transfers); counted in timed minute total. |
| 97535 | Self-care / home management training | Timed, 15-minute units | ADL compensatory training and safety instruction; counted in timed minute total. |
| 97161, 97162, 97163 | PT evaluation (low, moderate, high complexity) | Untimed, 1 unit | 1 unit max per visit; evaluation minutes stay out of the timed total (untimed code rules). |
| 97164 | PT re-evaluation | Untimed, 1 unit | For Medicare, documentation must support the need for further tests and measurements; routine progress assessment is not separately payable. See the re-evaluation note below. |
| 97010 | Hot or cold packs | Untimed (bundled) | Status indicator B on the Medicare RVU26D file (always bundled into payment for other services; see CO-97). |
| 97014 / G0283 | Electrical stimulation (unattended) | Untimed, 1 unit | Supervised modality; Original Medicare uses G0283 for covered conditions. |
Medicare 8-Minute Rule vs. CPT Midpoint Rule (“Rule of 8s”): Original Medicare adds all timed minutes for the day together to cap total timed units: 8–22 timed minutes = 1 unit, 23–37 minutes = 2 units, 38–52 minutes = 3 units, and 53–67 minutes = 4 units (CMS Pub. 100-04, Ch. 5, Sec. 20.2). Commercial payers that follow the AMA CPT midpoint rule (summarized by APTA) count each timed code on its own, requiring at least 8 minutes of that single code to bill 1 unit. Compare both rules side by side in our 8-minute rule vs. CPT rule of 8s guide and calculator.
Missing or mismatched therapy modifiers cause immediate front-end rejections or post-adjudication denials. Check these five modifiers against the treatment note before submitting a claim:
GP (Physical Therapy Plan of Care): Required on every “always therapy” code for Original Medicare outpatient physical therapy (CMS Chapter 5, Section 10.4). Claims without GP are returned as unprocessable under CO-4 (CARC 4: procedure code inconsistent with modifier).KX (Medical Necessity Threshold Attestation): Required on Original Medicare outpatient therapy claims once a beneficiary’s incurred therapy charges exceed the annual KX threshold—$2,480 in CY 2026 for physical therapy and speech-language pathology combined (with targeted medical review above $3,000). Omitting KX above the threshold triggers a CO-119 benefit maximum denial. Do not append KX routinely when the threshold is not approached (CMS Chapter 5, Section 10.3).CQ (Physical Therapist Assistant Services): Paired beside GP when a physical therapist assistant (PTA) independently furnishes more than 10% of a timed or untimed service under the CMS CQ/CO billing examples and Section 20.1 rules. Submitting CQ without GP causes a CO-4 unprocessable return.59 and XU (Distinct Procedural Service — NCCI Edits): Used only when two billed CPT codes hit a National Correct Coding Initiative (NCCI) procedure-to-procedure edit and clinical documentation supports a distinct, separate session or procedure (2026 Medicare NCCI Policy Manual). Compare CO-97 bundled PT codes and CO-236 modifier 59/XU rules.GA (Waiver of Liability / ABN on File): Indicates that a required Form CMS-R-131 Advance Beneficiary Notice of Non-coverage (ABN) was issued for Original Medicare therapy expected to be denied as not medically reasonable and necessary (CMS ABN Tutorial). Never use GA and KX together, and see CO-50 medical necessity denials for appeal vs. patient-liability rules.No claim rule matters until the therapist and the practice are enrolled with the payer. For Original Medicare, enrollment is a defined CMS process with dates that decide which visits can be billed at all. Medicare Advantage and commercial plans run their own credentialing and contracting, so confirm each plan’s requirements with that plan.
Sources: CMS, Become a Medicare Provider or Supplier, Enrollment Applications and Manage Your Enrollment (both last modified March 4, 2026), Revalidations (last modified July 29, 2025) and the Application Fee Matrix (PDF); 42 CFR 424.520 and 42 CFR 424.521. Checked November 9, 2026.
When a therapist is out sick, on leave or on vacation, Original Medicare lets the regular physical therapist bill for a substitute therapist’s visits only in limited circumstances. CMS no longer uses “locum tenens” for one arrangement. Its claims manual describes two: reciprocal billing arrangements and fee-for-time compensation arrangements. Commercial plans and Medicare Advantage plans set their own rules for covering therapists, so check each plan.
Source: CMS, Medicare Claims Processing Manual, Chapter 1 (PDF), sections 30.2.10 and 30.2.11 (Rev. 3774, effective June 13, 2017). Checked November 10, 2026.
A correctly coded Original Medicare claim can still pay less than the fee schedule amount on every line. Two CMS payment policies explain most of that difference, and two CY 2026 updates affect which remote services a therapist can bill. These are Original Medicare rules; Medicare Advantage and commercial plans set their own policies.
CQ modifier alongside GP.CQ is not required: under the CMS de minimis standard, the portion a PTA furnishes independently of the physical therapist must be reported with CQ only when it exceeds 10 percent of the total service or unit of service. Minutes the PTA and the PT furnish together count as the PT’s. CMS also defines two exceptions. First, when one final 15-minute unit is left to bill and the PT personally furnishes 8 or more minutes of it, that unit is billed without CQ. Second, when two units of the same service remain, the PT and the PTA each furnish between 9 and 14 minutes, and the combined time is at least 23 but no more than 28 minutes, one unit is billed with CQ and one without. Use the 8-minute rule calculator to check the unit count first.98966–98968, through December 31, 2027.98979, 98984 and 98985) to its therapy code list as “sometimes therapy” services and revised the descriptors of 98976 and 98977. Check the CMS 2026 Therapy Code List and Dispositions before billing them.Source: CMS, Therapy Services (CY 2026 Therapy Services Updates; page last modified March 10, 2026).
For Original Medicare outpatient therapy, review more than the billed code and minutes. CMS identifies missing evaluations, incomplete plans of care, certification problems and incomplete progress reports among common documentation errors. Use this focused checklist alongside the full CMS guidance; it is not a complete coverage checklist or a rule for every payer.
Source: CMS, Complying with Outpatient Rehabilitation Therapy Documentation Requirements, September 2025, pages 3–5. If a remittance requests therapy records, use the N900/N901 documentation guidance to distinguish missing from incomplete records and review the payer’s actual request.
When is a Medicare PT re-evaluation separately billable? Routine assessment of progress is part of ongoing therapy, not a separately payable re-evaluation. CMS says a formal re-evaluation is covered only when the documentation supports the need for further tests and measurements after the initial evaluation. Indications include new clinical findings, a significant change in the patient’s condition, or failure to respond to the interventions in the plan of care. A progress-report deadline alone does not establish that need. See the Medicare Benefit Policy Manual, Chapter 15, section 220.3 C. Check other payers’ requirements separately.
Each physical therapy claim pairs CPT procedure codes with ICD-10-CM diagnosis codes. For a therapy-only outpatient visit, the official guidelines say to “sequence first the diagnosis, condition, problem, or other reason for encounter/visit shown in the medical record to be chiefly responsible for the outpatient services provided during the encounter/visit,” and that “codes for other diagnoses (e.g., chronic conditions) may be sequenced as additional diagnoses.”
Source: ICD-10-CM Official Guidelines for Coding and Reporting, FY 2027 (CMS and NCHS; effective October 1, 2026 through September 30, 2027), Sections I.B.2, IV.H, IV.J and IV.L. A diagnosis the notes do not support is a common route to a CO-50 medical necessity denial.
For Medicare Part B, federal regulation says the claim “must be filed no later than the close of the period ending 1 calendar year after the date of service.” Limited exceptions exist, such as an error by a Medicare contractor or retroactive Medicare entitlement, and a deadline that falls on a federal nonworkday moves to the next workday (42 CFR 424.44). Commercial and Medicare Advantage plans set their own filing limits in the payer contract, so check each one. A late claim usually comes back as CO-29.
CMS says group therapy “consists of simultaneous treatment to two or more patients who may or may not be doing the same activities.” If the therapist is dividing attention among patients, giving only brief, intermittent personal contact, or giving the same instructions to two or more patients at the same time, CMS says “it is appropriate to bill each patient one unit of group therapy, 97150 (untimed).” Timed one-on-one codes need direct one-on-one contact, counted under the 8-minute rule.
97150) and separate one-on-one timed services (such as 97110 or 97140) on the same date of service, the one-on-one minutes must occur in a separate, non-overlapping time interval and be billed with modifier -59 (or the applicable X subset modifier) to show distinct procedural service (Scenarios 3 and 4).97530, or either one could bill both units, but not both therapists. Source: CMS, MDS 3.0 RAI User’s Manual, v1.20.11 (effective October 1, 2026), Chapter 3, Section O, pages O-26 and O-38. Checked November 10, 2026.97150 or as a skilled timed code, and time a patient spends exercising independently on equipment without skilled therapist intervention is not separately billable (Scenarios 8 and 9).Source: CMS, 11 Part B Billing Scenarios for PTs and OTs (Scenarios 3, 4, 6, 7, 8 and 9).
Traditional paper-based billing methods can be time-consuming, prone to errors, and inefficient. Implementing digital billing solutions in physical therapy practices offers several advantages, including:
Digital billing solutions automate various aspects of the billing process, eliminating manual tasks and reducing paperwork. This streamlines workflow and allows staff to focus more on patient care rather than administrative tasks.
Use software checks to flag items for review before claim submission; do not treat a passed software check as proof that the coding is correct or that the claim will be paid. Compare the billed services and units with the treatment documentation and applicable payer requirements.
Electronic transmission is not the same as payment approval. For Original Medicare, CMS describes front-end and implementation-guide checks followed by coverage and payment-policy edits; claims can still be rejected or denied. Review the acknowledgment and any error response rather than assuming that sending a claim completes the process. See CMS: How Electronic Claims Submission Works. Other payers may use different workflows.
When evaluating a billing system, check how staff retrieve treatment records, track changes, and connect documentation to the submitted claim. Do not treat electronic storage alone as proof of compliance. For Medicare outpatient therapy, review the CMS documentation requirements alongside the actual clinical record, not just the software’s available features.
When evaluating billing reports, ask which data sources they use, when each source was last updated, and whether claim status, remittance information and posted payments are shown separately. Do not assume a dashboard labeled “real-time” contains a final payer decision. For Original Medicare, CMS states that remittance advice is sent after a claim is processed and includes final adjudication and payment information. Check report totals against the underlying remittance and payment records before using them to assess collections. See CMS remittance advice guidance.
Under HIPAA administrative simplification rules, the national standard for submitting professional physical therapy claims electronically is the ASC X12N 837P (Version 5010, 005010X222A1) transaction (45 CFR 162.1102(c)(3)). Federal Medicare regulations require providers and suppliers to submit Part B claims electronically unless a statutory exception applies—such as the small-supplier exception for practices with fewer than 10 full-time equivalent employees—in which case the prescribed paper claim form is the CMS-1500 (42 CFR 424.32(b) and (d)(2)–(4)). After adjudication, payers return line-item payment and adjustment data using the ASC X12N 835 (005010X221A1) Health Care Claim Payment/Advice standard, commonly called the Electronic Remittance Advice (ERA) (45 CFR 162.1602(c)), which pairs group codes (CO, PR, OA, PI) with CARC and RARC denial and remark codes.
A physical therapy EMR or practice-management scrubber can do more than check whether required fields are populated. Available checks depend on the product and configuration: for example, WebPT documents CCI-edit and ICD-10 Excludes1-conflict settings. Confirm which checks your system applies and whether its payer settings match your contracts. After claim creation, assign responsibility for these four downstream revenue-cycle tasks:
277CA): resolving front-end rejections for subscriber ID mismatches, rendering/billing NPI enrollment gaps, or invalid ICD-10 pointers before the claim ever enters payer adjudication.835 ERA payment verification: auditing paid units against your contracted fee schedule and Medicare MPPR calculations rather than letting auto-posting rules write off underpayments hidden behind CO-45 contractual adjustment codes.835 adjudication leaves coinsurance, deductible, or copay balances (PR-1, PR-2, PR-3).When deciding whether to keep billing in-house or partner with an outsourced physical therapy billing company, compare both staffing overhead and daily revenue-cycle execution. Across the market, outsourced PT billing typically ranges from 4% to 8% of collections (per the July 2026 Medical Billing Rates guide; a market range, not ePT’s price), while ePT Billing’s published rate is 4.75% of collections. By comparison, one full-time in-house billing clerk costs about $5,125 a month in wage and benefits alone ($46,630 median annual wage in therapy offices per May 2025 BLS data, plus 31.9% for benefits from June 2026 BLS employer cost data), before software, clearinghouse fees, and office space—meaning a 4.75% fee equals one full-time biller’s direct cost at about $107,903 of monthly collections. Run your own practice numbers in our physical therapy billing cost calculator.
A billing company takes over the claim work that follows the visit. At ePT Billing that means submitting primary and secondary claims daily, checking CPT codes, timed units and modifiers before claims go out, posting EOBs and ERAs within 24 hours of receipt, investigating denials and correcting or appealing them, and following up on unpaid claims with a monthly insurance aging report. The table below compares each task with in-house staffing, and the full list is on Our Services.
| Factor | In-House Billing Staff | Outsourced PT Billing (ePT Billing Scope) |
|---|---|---|
| Monthly cost structure | About $5,125/month in wage + benefits per full-time biller (BLS benchmark), plus software and clearinghouse costs. | 4.75% of collections at ePT Billing (equals one full-time biller at ~$107,903/month collected; check whether any minimum applies in our cost guide). |
| Claim submission cadence | Can batch or backlog when front-desk duties or staff absences intervene. | Primary and secondary claims submitted daily so claims enter adjudication without delay. |
| EOB & ERA payment posting | Depends on single-biller bandwidth. | All EOBs posted daily within 24 hours of receipt to keep patient balances and A/R accurate. |
| Procedure & modifier review | Relies on internal staff training in PT timed units and payer edits. | Daily procedure verification for CPT codes, timed units, and modifiers (95% first-pass claim acceptance rate highlighted on Our Services). |
| Denial appeals & aging A/R | 30/60/90+ day unpaid claims often wait behind daily charge entry. | Immediate denial investigation, corrections or appeals (top PT claim denials), plus full monthly insurance aging report follow-up and accountability reports (with a 30-day free trial on Our Services). |
For a specific payment adjustment, start with our physical therapy denial-code guide. If you are comparing staffing options, use the billing cost calculator and its assumptions. To compare service responsibilities rather than software features, review what ePT Billing handles for your practice.
Comparing billing companies? Use our 12-question PT billing company checklist to compare fees, reporting, service responsibilities and contract terms.
[2] Centers for Medicare & Medicaid Services, Complying with Outpatient Rehabilitation Therapy Documentation Requirements, September 2025, pages 3, 6–7. The Medicare-specific guidance above should not be treated as a universal rule for every insurance plan.