Articles August 1, 2014

The 8 Minute Rule

By Marty Kotlar, DC, CHCC, CBCS
Download a printable copy HERE.

Question: I often bill 2-3 time-based codes per visit. Do I have to spend at least 8 minutes or 15 minutes per procedure code in order to bill properly?

Answer: Unfortunately, the answer to your simple question is not simple. I’ll first provide general recommendations and suggestions, and then I’ll give you a few specific examples.

To begin with, for any single timed CPT code in the same day measured in 15-minute units, providers should bill a single 15-minute unit for treatment greater than or equal to 8 minutes through and including 22 minutes. If the duration of a single procedure in a day is greater than or equal to 23 minutes through and including 37 minutes, then 2 units should be billed.

Time intervals for 1 through 4 units are as follows:

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

If a service represented by a 15 minute timed code is performed in a single day for at least 15 minutes, that service shall be billed for at least one unit. If the service is performed for at least 30 minutes, that service shall be billed for at least two units, etc. It is not appropriate to count all minutes of treatment in a day toward the units for one code if other services were performed for more than 15 minutes. When more than one service represented by 15 minute timed codes is performed in a single day, the total number of minutes of service as noted in the chart above determines the number of timed units billed.

If any 15 minute timed service that is performed for 7 minutes or less than 7 minutes on the same day as another 15 minute timed service that was also performed for 7 minutes or less and the total time of the two is 8 minutes or greater than 8 minutes, then bill one unit for the service performed for the most minutes. The same logic is applied when three or more different services are provided for 7 minutes or less than 7 minutes.

The expectation is that a provider’s direct patient contact time for each unit will average 15 minutes in length. If a provider has a consistent practice of billing less than 15 minutes for a unit, these situations could be highlighted for review. If more than one 15 minute timed CPT code is billed during a single calendar day, then the total number of timed units that can be billed is constrained by the total treatment minutes for that day. The amount of time for each specific modality/therapeutic procedure provided to the patient should be documented in the SOAP notes.

Example #1
8 minutes of therapeutic exercise (97110)
8 minutes of manual therapy (97140)
TOTAL = 16 timed minutes

The appropriate billing in this example is 1 unit. You should select 97110 or 97140 to bill since each unit was performed for the same amount of time and only 1 unit is allowed.

Example #2
7 minutes of neuromuscular reeducation (97112)
7 minutes of therapeutic exercise (97110)
7 minutes of manual therapy (97140)
TOTAL = 21 timed minutes

The appropriate billing in this example is 1 unit. You should select 1 code (97112, 97110 or 97140) to bill since each unit was performed for the same amount of time and only 1 unit/1 code is allowed.

Example #3:
33 minutes of therapeutic exercise (97110)
7 minutes of manual therapy (97140)
TOTAL = 40 timed minutes

The appropriate billing in this example is 3 units. You should bill 2 units of 97110 and 1 unit of 97140. Count the first 30 minutes of 97110 as two full units. Compare the remaining time for 97110 (33-30 = 3 minutes) to the time spent on 97140 (7 minutes) and bill the larger, which is 97140.

Example #4:
24 minutes of manual therapy (97140)
23 minutes of therapeutic exercise (97110)
TOTAL = 47 timed minutes

The appropriate billing in this example is 3 units. Each of the codes is performed for more than 15 minutes, so each should be billed for at least 1 unit. The correct way to code this example is 2 units of 97140 and 1 unit of 97110, assigning more timed units to the service that took the most time.

Example #5:
18 minutes of therapeutic exercise (97110)
13 minutes of manual therapy (97140)
10 minutes of therapeutic activities (97530)
8 minutes of ultrasound (97035)
TOTAL = 49 timed minutes

The appropriate billing in this example is 3 units. You should bill the procedures you spent the most time providing. Bill 1 unit each of 97110, 97140 and 97530. You should not bill for the ultrasound because the total time of timed units that can be billed is constrained by the total timed code treatment minutes (i.e., you may not bill 4 units for less than 53 minutes regardless of how many services were performed). You should still document the ultrasound in the SOAP notes.

End of article info:
Marty Kotlar, DC, CHCC, CBCS is the President of Target Coding. Dr. Kotlar is Certified in CPT Coding, Certified in Healthcare Compliance and has been helping healthcare providers nationwide document properly, get paid properly and prevent insurance audits for over 10 years. Target Coding can be reached at 1-800-270-7044, website – www.TargetCoding.com, email – info@targetcoding.com.