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Billing CPT Codes with the "8" Minute Rule

Kathleen D. Weissberg, OTD, OTR/L, CMDCP, CDP

June 22, 2018

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Question

Can you explain the "8" minute rule and go over a few billing examples corresponding to correct CPT coding?  

Answer

The first step when billing timed CPT codes is to total the minutes for all timed modalities and procedures provided to the patient on a single date of service for a single discipline. Now if you have a single timed code service, that's pretty easy. If you have multiple timecode services, it doesn't really matter whether it's single or if it's multiple CPTs, your total number of units that you can bill in any one day is constrained by the total treatment time of timed codes. For example, a patient under a PT plan of care receives skilled treatment consisting of 20 minutes of therapeutic exercise (CPT 97110) and 20 minutes of gait training (CPT 97116).  The total “Timed Code Treatment Minutes” documented will be 40 minutes. Whether a single timed code service is provided, or multiple timed code services, the skilled minutes documented in “Timed Code Treatment Minutes’ will determine the number of units billed.

If more than one 15-min timed code is billed on a calendar day, the total number of units that can be billed is constrained by the total treatment time. There are examples to follow that will illustrate these rules.  

Once the minutes have been summed, use the chart below to determine the total allowable units, based on the total Timed Code Treatment 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 

6 units > 83 minutes through 97 minutes 

7 units > 98 minutes through 112 minutes 

8 units > 113 minutes through 127 minutes

When the total Timed Code Treatment minutes for the day is less than 8 minutes, the service(s) should not be billed.

When we are documenting our treatment time, do not record your treatment time as time in and time out for the entire session, because that really doesn't accurately reflect the actual treatment time. We need to look at our minutes by CPT code (therapeutic intervention) that we provided. Additionally, we do not round minutes to the nearest zero or 5.  We need to record the exact minutes of treatment time you spend with your patient.  Don't record "units" of treatment instead of minutes. It is best practice to record your minutes and then convert those minutes over to units. In addition, remember that you're only billing the time which is skilled.  Do not include unbillable time, such as time for changing, waiting for treatment to begin, waiting for equipment resting, toileting, or performing unskilled or independent exercises or activities.

It's important to allocate your total billable time to the appropriate CPT codes. Any timed service provided for at least 15 minutes need to be billed one unit. Any timed service provided for at least 30 minutes must be billed for two units and so on and so forth. So when you're determining the allocation of units, it's easiest to separate out first into 15-minute blocks.

For example, we performed 20 minutes of Therex, so that's one 15 minute block and five remaining minutes. So we know we need to allocate at least one unit to this code. We also performed 38 minutes of therapeutic activities, so that's 30 minutes, we know that we have two 15 minute blocks and eight remaining minutes. So we have to have at least two units allocated to that code. And then what we didn't include there is the G0283, which would be an untimed code. So let's go into some other examples, and I think this will probably bring it all together.

Example patient 1. Patient is s/p hip fracture. We spent 24 minutes of balance strategy retraining and 23 minutes of lower extremity exercises for strength. How would you bill that? In this case, we would have two units of Neuromuscular re-education 97112, and one unit of 97110 therapeutic exercise. So the question is why?

47 minutes falls within the range for 3 units. To allocate those 3 units determine the 15-minute blocks first

24 minutes 97112 = one 15-minute block + 9 remaining minutes 

23 minutes 97110 = one 15-minute block + 8 remaining minutes 

Each code contains one 15-minute block; therefore, each code shall be billed for at least 1 unit. Since the total minutes allows for 3 units, the third unit shall be applied to the service with the most “remaining minutes” (97112 has 9 remaining minutes, whereas, 97110 has 8 remaining minutes). The correct coding, therefore, is 2 units 97112 + 1 unit 97110

Example patient 2. We have another patient that is s/p hip fracture.  We treated this patient 20 minutes on balance strategy retraining and 20 minutes of lower extremity exercises for strengthening. This example includes the same CPT codes but just a small change in the number of minutes. We have 40 minutes of total treatment time which falls into the range for three units. 

40 minutes falls within the range for 3 units. To allocate those 3 units determine the 15-minute blocks first 

20 minutes 97112 = one 15-minute block + 5 remaining minutes 

20 minutes 97110 = one 15-minute block + 5 remaining minutes 

Each code contains one 15-minute block, therefore, each code shall be billed for at least 1 one unit. As 3 units is allowed, a review of the “remaining minutes” is required to determine which code should be billed the additional unit. Since the “remaining minutes” for each service are the same in this example, either of the codes may be billed for the additional unit. That is up to you the clinician to determine where that extra unit goes. The correct coding is either one of the following 2 units 97112 + 1 unit 97110 OR 1 unit 97112 + 2 units 97110

Example patient 3. Patient is s/p rotator cuff repair. Treatment time included four minutes assessing the shoulder strength prior to initiating and progressing the therapeutic exercise, thirty-two minutes of range of motion instruction and seven minutes of joint mobilization.  So how are you billing this? We have 36 total minutes of therapeutic exercise which is two 15 minute blocks and six remaining minutes.  Under joint mobilization, we only have seven minutes.  You might be thinking, well wait a second, that's under eight minutes, I can't bill that. But as shown below, we have six minutes of Therex left over and seven minutes of manual therapy left over. Which one gets the unit? It has to be manual therapy because seven minutes left over is great than six.

36 minutes 97110 = two 15-minute blocks + 6 remaining minutes 

7 minutes 97140 = zero 15-minute blocks + 7 remaining minutes

Code 97110 must be billed for at least 2 units as it contains two 15-minute blocks. To determine the allocation of the third unit, compare the “remaining minutes”, and apply the additional unit to the service with the most remaining minutes. The correct coding is 2 units 97110 + 1 unit 97140


kathleen d weissberg

Kathleen D. Weissberg, OTD, OTR/L, CMDCP, CDP

Kathleen Weissberg, OTD, OTR/L, in her 25 years of practice, has worked in adult rehabilitation, primarily in long-term care as a clinician, manager, researcher, and most recently as Education Director with Select Rehabilitation where she oversees continued competency and education for close to 12,000 therapists. In her role, she conducts audits and provides denials management and quality improvement planning training for more than 700 LTC sites nationwide. She also conducts compliance, ethics, and jurisprudence training to therapists.  Kathleen has authored several publications that focus on patient wellness, fall prevention, dementia management, therapy documentation, and coding/billing compliance.  

 


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