Dynamic Chiropractic – April 23, 2007, Vol. 25, Issue 09

Billing Units of Service: The Element of Time

By Samuel A. Collins

Q: My doctor performed 10 minutes of exercise (97110) and 10 minutes of neuromuscular re-education (97112) on a single visit. Is it appropriate to bill one unit of each of these services, since she performed more than eight minutes of each service?

A: First, in the above example, it would not be appropriate to bill each at one unit.

Instead, only one of the services is billed, as the time component of the procedures is considered cumulative, even though two different timed services were performed. And because the total time spent on both procedures does not exceed the amount to qualify to bill for two units, only one unit is allowed. The minimal time needed to qualify for two units of service is 23 minutes (with a maximum of 37 minutes). In the example, you noted that 10 minutes were spent on each, which is a total of only 20 minutes. In this case, you would bill the higher-valued code at one unit. The other service not billed is, of course, documented in the chart notes, but is not separately billed.

To qualify for one unit of each service, the total time spent would have to be at least 23 minutes. Therefore, to qualify to bill each service for one unit, services would require a minimum of eight minutes on any single procedure, with a cumulative time of 23-37 minutes spent performing both services. In this scenario, one service might be 10 minutes and the other 15 minutes, with the cumulative total of 25 minutes, thus exceeding the 23-minute minimum requirement. (Note: If a service is done for less than eight minutes, regardless of the cumulative total of all services, it should not be separately billed.)

Per CMS coding rules and AMA current procedural terminology guidelines, if more than one CPT code is billed during a calendar day, the total number of units that can be billed is constrained by the total treatment time of the procedures. For example, if 24 minutes of code 97112 and 23 minutes of code 97110 were furnished, the total treatment time would be 47 minutes. Therefore, only three units can be billed for the treatment. The correct coding is two units of code 97112 and one unit of code 97110, assigning more units to the service that took the most time. A minimum of 53 minutes must be spent to qualify for four units of service. In assigning units, use the following chart:

Units Reported on the Claim Minutes Spent Performing Service
One unit ≥ 8 minutes to ≤ 23 minutes
Two units ≥ 23 minutes to ≤ 38 minutes
Three units ≥ 38 minutes to ≤ 53 minutes
Four units ≥ 53 minutes

In determining the time frame of a service, the time starts when the chiropractor is working directly with the patient. Note that pre- and post-delivery services are not to be counted in determining the treatment service time. In other words, the time counted as "intraservice care" begins when the chiropractor (or an assistant under the supervision of a chiropractor - this may or may not be allowed in some states. So check your individual state requirements) is directly working with the patient to deliver treatment services. The patient should already be in the treatment area (e.g., on the treatment table or mat, or in the gym) and prepared to begin treatment.

The time counted is the time during which the patient is treated. For example, if doing therapeutic activities that involve the patient doing overhead throwing and catching, each 15 minutes the patient is being treated can count as only one unit of CPT code 97530. The time the patient spends not being treated because of the need for toileting or resting should not be billed. In addition, the time spent waiting to use a piece of equipment or for other treatment to begin is not considered treatment time.

Be sure to document the amount of time for each service to the minute in your treatment or daily SOAP notes.


  • CMS guidelines regarding time-based codes are discussed in CMS Pub. 100-4, Chapter 5.

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