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Billing Example Using the 8 Minute Rule

Mary R. Daulong, PT, CHC, CHP

March 2, 2016



Can you explain a more difficult example when using the 8 minute rule?  


Medicare, the 8-minute rule does not distinguish between which timed codes are billed.  It focuses on the total minutes.  It combines the minutes for the same procedure, but it allows a half-way point calculation when those CPT codes are different. 

Here is a simple CMS scenario on their website.  It shows:

·       33 minutes of therapeutic exercise (97110)

·       7 minutes of manual therapy (97140)

·       40 Total timed minutes

What do you think would be billed?  How many units would be billed?  A lot of people say “only 7 minutes of manual therapy and we didn’t meet the 8 minutes; so they are taking it away and we are losing it.”  One of the reasons CMS went to total time is so we did not lose those seven minutes or less if they are combined with another timed code.  We would, in that circumstance, bill two units of exercise and one unit of manual therapy.  We are going to count the first 30 minutes (two units) of exercise as two full units.  We are not going to throw away those three minutes that are dangling.  We would then look at the seven minutes of manual therapy and three minutes of exercise; this combined makes another unit.  Seven minutes is greater than three minutes so you would defer to manual therapy as the appropriate additional code.  

mary r daulong

Mary R. Daulong, PT, CHC, CHP

Mary Daulong, PT, CHC, CHP is a physical therapist and is also certified in Healthcare Compliance by the Health Care Compliance Certification Board and the HIPAA Academy. Her consulting company, Business & Clinical Management Services, Inc. was established in 1985 and has been, for the past dozen years, 100% dedicated to working with rehab professionals in the areas of federal and state compliance, provider enrollment, practice and business office audits/surveys, payment policy: billing, coding, documentation and compliance policy and procedure manual production.

Mary is the former chair of the TPTA’s Payment Policy Committee, is a member of the Private Practice Payment Policy Committee and is the representative for PT & OT for Jurisdiction JH. She is also on Novitas Solutions’ Provider Outreach Education Advisory Board and has been recently served on Novitas Solutions’ JH Transition Consulting Team.

Mary has been a featured speaker at National, State and Section Annual Conferences and is one of the contributing authors to “Compliance Corner” for the Private Practice Section’s Impact Magazine. 


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