
Medicare’s 8-Minute Rule: A Step-by-Step Guide
What is the 8-Minute Rule?
Medicare’s 8-Minute Rule dictates how outpatient therapy providers (physical, occupational, and speech therapists) convert time-based services into reimbursable units. This rule ensures accurate billing for timed procedures like therapeutic exercises or manual therapy.
Core Principles
- 1 Unit = Minimum of 8 minutes (up to 22 minutes) of one timed service
- Total Time Aggregation: Combine minutes from all timed codes in a session to calculate units (e.g., 38 total minutes = 3 units).
- Untimed Services: Evaluations or assessments are billed as 1 unit, regardless of time spent.
Real-World Examples to Simplify Compliance
Case 1: Physical Therapy Session
- Therapeutic Exercise (97110): 25 minutes
- Manual Therapy (97140): 12 minutes
- Total Timed Minutes: 37 → 2 units (covers 23–37 minutes)
- Evaluation (97161): 1 unit (untimed)
- Total Billed: 3 units
Case 2: Occupational Therapy Session
- Neuromuscular Re-Ed (97112): 45 minutes
- Ultrasound (97035): 7 minutes (Not billable — less than 8 minutes)
- Total Timed Minutes: 45 → 3 units (38–52 minutes)
Quick-Reference Chart for Timed Services
Total Minutes | Units Billed | Common CPT Codes |
8–22 | 1 | 97110, 97530, 97140 |
23–37 | 2 | 97112, 97116, 97150 |
38–52 | 3 | 97535 (Self-Care Training) |
53–67 | 4 | 97763 (Orthotics Management) |
Timed vs. Untimed Codes: What’s the Difference?
Timed Codes (Follow 8-Minute Rule) | Untimed Codes (1 Unit Always) |
97110 (Therapeutic Exercise) | 97161 (PT Evaluation) |
97140 (Manual Therapy) | 97165 (OT Evaluation) |
97530 (Therapeutic Activities) | 92507 (Speech Sound Assessment) |
- When a time-based service reaches the eight-minute mark, you can bill Medicare for one billable unit.
- This first billable unit applies to services that last between eight and 22 minutes.
- For services exceeding 22 minutes, you bill in 15-minute increments, accumulating additional billable units.
Avoid Costly Errors: Top 3 Mistakes
- Mixing Timed/Untimed Codes: Billing untimed services (e.g., evaluations) based on time spent.
- Fix: Always bill 1 unit for untimed codes, even if they take 45 minutes.
- Over-Rounding: Assuming 22 minutes = 2 units (it’s 1 unit for 8–22 minutes).
- Ignoring the 8-Minute Threshold: Services under 8 minutes earn $0 reimbursement.
Pro Tip: Use tools like Therabill or Cliniko to auto-calculate units and reduce errors.
Conclusion
The Medicare 8-Minute Rule is a crucial tool that healthcare providers must understand and apply correctly. It not only facilitates fair and accurate billing but also upholds the principle of providing necessary care to patients while preventing excessive charges. As you navigate the complexities of Medicare billing, a solid grasp of the 8-Minute Rule will serve you well, benefiting both your practice and the healthcare system as a whole.
Frequently Asked Questions (FAQs)
Absolutely! Add their minutes (e.g., 15 + 10 = 25 minutes → 2 units).
53 minutes = 3 units (38–52 mins) + 1 non-billable minute.
The CO-24 denial code (“Charges exceed contracted/legislated fee arrangement”) occurs when billed amounts exceed a payer’s allowed rate. Here’s how to resolve it:
- Compare Billed vs. Allowable Rates
- Check the payer’s fee schedule (e.g., Medicare Physician Fee Schedule, Medicaid portal).
- Example: If Medicaid allows 75forCPT99213, forCPT99213, butyoubilled100, adjust the charge.
- Apply Modifiers
- Use -CO (Contractual Obligation) to indicate you’ve adjusted the charge to the payer’s rate.
- Add -GA (Waiver of Liability) if the patient agreed to pay the difference.
- Adjust & Resubmit
- Reduce the charge to the allowable amount and resubmit the claim with modifier -CO.
- Prevent Future Denials
- Update billing software with the latest payer fee schedules.
- Use pre-bill audits to flag overcharges.
The CO-22 denial code (“Missing/invalid information”) happens when critical data is missing or incorrect. Fix it with these steps:
- Review the Claim for Errors
- Missing patient ID, DOB, or policy number.
- Incorrect CPT/HCPCS codes (e.g., using 99214 instead of 99213).
- Verify Patient & Payer Details
- Cross-check patient demographics with insurer records.
- Confirm prior authorization or referral numbers.
- Correct & Resubmit
- Fix typos (e.g., transposed digits in the policy number).
- Attach missing documents (e.g., referral forms).
- Prevent Recurrence
- Use EHR templates with auto-populated fields.
- Train staff on double-checking claims.
Use the Medicare Fee Schedule Lookup Tool before billing.


