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Medicare 8 Minute Rule for Physical Therapy: Complete Guide

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The 8 minute rule is a Medicare guideline used to determine how to bill for timed therapy services (physical, occupational, and speech therapy). The services are billed based on time spent performing therapeutic activities, not just sessions or appointments. And this applies only when the therapy is timed, i.e., codes where time dictates billing.

Types of the 8 Minute Rule

  • PT 8 Minute Rule – exercise, gait training, manual therapy.
  • OT 8 Minute Rule – ADL, functional activities, splinting.
  • ST 8 Minute Rule – articulation, language, and swallowing therapy.

Application of the Medicare 8 Minute Rule

  • Applies to Medicare Part B therapy services: PT (Physical Therapy), OT (Occupational Therapy), ST (Speech Therapy).
  • Used when therapy sessions include multiple timed activities.
  • Applicable to Medicare beneficiaries; other insurance may not follow the 8-minute rule.
  • Some private insurers adopt a similar “time-based” billing system, but only Medicare mandates the 8-minute calculation.

Does it Only Apply to Medicare?

  • Yes, the 8-minute rule is a CMS/Medicare-specific billing guideline.
  • Private insurance often uses unit-based billing, not necessarily the 8-minute rule.
  • If billing non-Medicare patients, verify payer rules.

Types of Therapy Using the 8-Minute Rule

  • Physical Therapy (PT) – most common.
  • Occupational Therapy (OT) – applies for timed functional activities.
  • Speech Therapy (ST) – applies for timed speech/language activities.

Types of Therapy Using the 8-Minute Rule

Medicare 8 Minute Rule Quick-Reference Chart

Following is a 8-minute rule table for easy coding:

Therapy Type

CPT Code

Timed?

Time Range (Minutes)

Units

Modifier

Notes / CMS Guidance

Physical Therapy

97110 – Therapeutic Exercise

Yes

8–22

1

GP

Exercises, strengthening, range of motion

Physical Therapy

97110

Yes

23–37

2

GP

2 units = add 15 min total

Physical Therapy

97110

Yes

38–52

3

GP

Add units per 15 min increments

Physical Therapy

97112 – Neuromuscular Re-education

Yes

8–22

1

GP

Includes balance, coordination

Physical Therapy

97116 – Gait Training

Yes

8–22

1

GP

Each 15 min increment = 1 unit

Physical Therapy

97530 – Therapeutic Activities

Yes

8–22

1

GP

Functional activities, timed

Occupational Therapy

97165 – Evaluation (Low Complexity)

No

N/A

1 per session

GO

Not timed, one per session

Occupational Therapy

97535 – Self-Care/Home Management

Yes

8–22

1

GO

ADL or functional activity

Occupational Therapy

97110 – Therapeutic Exercise

Yes

8–22

1

GO

Same PT code can be OT if functional

Speech Therapy

92507 – Treatment of Speech/Language

Yes

8–22

1

GN

Timed speech-language therapy

Speech Therapy

92523 – Eval of Speech/Language

No

N/A

1 per session

GN

Non-timed evaluation

Speech Therapy

92526 – Treatment of Swallowing

Yes

8–22

1

GN

Swallowing/feeding therapy, timed

8 Minutes Rule Calculation

Please note that providers are suggested not to bill in case only 1 service is provided in a day, and that too was performed in less than 8 minutes. Here is how you may calculate:

  • Direct, one-on-one therapy time counts.
  • Include time for:
    – Therapeutic exercises
    – Manual therapy
    – Gait training
    – Functional activities (OT/ST)
  • Documentation must specify start and end times for each timed activity.
  • Rule of thumb:
    – 1 unit = 8-22 minutes
    – 2 units = 23-37 minutes, etc.

Round down to the nearest unit if under 8 minutes.

For step-wise assistance, you may find it useful to check out the CMS regulations and guidance manual.

Note: While the 8-Minute Rule defines how therapy minutes are billed under Medicare, insurance providers such as UnitedHealthcare also require prior authorization for therapy services. Learn more about UnitedHealthcare’s new prior authorization rules here.

8-Minute Rule Calculation Notes (CMS Verified)

Following these notes may help you avoid expensive denials:

  • Timed codes = codes where Medicare reimburses by minutes spent.
  • 1 unit = 8–22 minutes, 2 units = 23–37 minutes, 3 units = 38–52 minutes, etc.
  • Round down to nearest unit if total minutes < 8 (no unit).
  • Document start and stop times for each activity to support billing.
  • Combine multiple timed codes carefully—each must meet the 8-minute threshold individually.
  • Apply correct modifier (GP, GO, GN) for therapy type.
  • Category: Timed CPT codes = Category 1.

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Step-by-Step Coding Process for 8 Minute Rule

Implementation of the 8-minute rule made easy:

Step 1: Identify timed CPT codes.

  • PT: 97110, 97112, 97116, 97530, etc.
  • OT: 97165-97168, 97535, 97110, 97112, etc.
  • ST: 92507, 92523, 92526, etc.

Step 2: Track Total Therapy Minutes per Session

  • Note start and end times.
  • Count only skilled, billable minutes.
  • Exclude rest, documentation, or non-therapeutic time.

Step 3: Apply the 8-minute billing rule

  • 8–22 minutes = 1 unit
  • 23–37 minutes = 2 units
  • 38–52 minutes = 3 units, and so on.

Step 4: Use the correct modifier if needed

  • GP = PT services
  • GO = OT services
  • GN = ST services

Step 5: Document everything in the medical record.

Step-by-Step Coding Process for 8 Minute Rule

Practical Tips for Doctors, Clinics, and Billers

  • Always document the exact minutes spent on each activity.
  • Break down activities by CPT code; do not lump them all together.
  • Check CMS guidelines for therapy caps and exceptions.
  • Use Hello MDS or your EHR to track timed therapy sessions accurately.
  • Be aware of the rule of 8s (sometimes confused with 8-minute rule) – it’s the same principle for unit calculation.
  • Do not bill units <8 minutes; this will likely be denied.
  • Periodically review CMS 8-minute rule guidelines for updates.

Bottom Line

The Medicare 8-minute rule physical therapy ensures accurate, compliant billing for timed therapy sessions. Track time meticulously, code correctly, and you’ll maximize reimbursement while staying fully compliant. Or simply consider offloading your administrative tasks to a HIPAA-compliant medical billing company like Hello MDs.

Disclaimer: This blog is for informational purposes only and does not constitute medical, legal, or professional advice. While we strive for accuracy, errors or omissions may occur.

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