The 8-minute rule for therapy billing

8 minute rule; eight minute rule; time based codes; timed CPT codes

The 8 minute rule allows therapists to determine the number of units they can bill for a specific timed service. In addition to knowing what the 8 minute rule is, it’s also important for therapists to understand when it starts, how it works, and the difference between time-based vs service-based codes. We’ll cover this information as well as provide examples and tips.

What is the 8 minute rule?

Rehabilitation therapists commonly use the 8 minute rule for billing the time they provide services to a patient. The 8 minute rule is well-known because it is used by Medicaid and other (but not all) private insurers. The accuracy of billing reflects upon the professional practices and ensures that all health professionals adhere to their code of ethics. The 8 minute rule provides the precision that benefits therapists, patients, and reimburses alike.   

The 8 minute rule helps therapists determine the number of units they can bill for a specific timed service. Service units for therapy occur in 15-minute increments. For example, a 30-minute session would be billed and reimbursed for two units.  

When does the 8 minute rule start?

With the 8 minute rule, the timer begins when you start providing skilled services.  It is important to remember that gathering information, assessing, and educating the patient are part of skilled services, particularly when you use that information to guide intervention strategies. 

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How does the 8 minute rule work?

According to CMS, “For any single timed CPT code in the same day measured in 15-minute units, providers 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 modality or procedure in a day is greater than or equal to 23 minutes through and including 37 minutes, then two units should be billed.” 

Therefore, if you are only using one CPT code, record the number of minutes for that intervention and convert it to billable units accordingly. 

Here is an easy-to-use table to convert the amount of time spent with the patient into billable units:

Time Delivered

Billable Units

Less than 8 minutes


8-22 minutes


23-37 minutes


38-52 minutes


53-67 minutes


68-82 minutes


83-97 minutes


Time-based vs. service-based codes

So far, we have been looking at timed CPT codes. Not all CPT codes are time-based, however.  Evaluations and certain modalities are service-based. Rather than request payment for one 35-minute evaluation or one 20-minute evaluation, you'll bill for one evaluation regardless of how much time you spent. Time-based codes that are written in 15-minute increments follow the eight-minute rule. 

Frequently used time-based rehabilitation codes include:
  • 97110 – Therapeutic exercise
  • 97140 – Manual therapy
  • 97530 – Therapeutic activities
  • 97542 – Wheelchair management/propulsion training
  • GO515 – Cognitive skills development

It is important to note that some codes are timed but do not fit into the eight-minute rule since one unit is more than 15 minutes.

For example: 
  • 96105 – Assessment of aphasia (1 hour)

  • 92608 – Assessment for non-speech generating device (1 hour)

Instead of the 8 minute rule, divide the amount of time on the code by two for these codes.  Generally, if you have spent at least half of the time that the code is allotted, you can bill another unit. 

Untimed codes

Untimed codes will generally have one fee per code regardless of the time spent delivering the service. Many speech-language pathology services, OT and PT evaluations, and some modalities fall into this category.  

However, there is a modifier for when these services take an unusually long time to deliver.  Use modifier 22 in these cases, but document the reason for the extra time.  

The use of this modifier can increase reimbursement in some cases. 

Service-based untimed rehabilitation codes include: 
  • 92506 – Speech/hearing evaluation

  • 95833 – Manual muscle testing

  • 97001/97002 – Physical therapy evaluation/re-evaluation

  • 97003/97004 – Occupational therapy evaluation/re-evaluation

  • 97014 – Electronic muscle stimulation

  • 97101 – Hot/cold packs (bundled code that therapists must use with another service)

The 8 minute rule does not apply to the above services. 


A therapist supports a client in propelling their new wheelchair through their home.  They work together for 39 minutes, and the therapist intends to use CPT code 97542.  The therapist should write down the exact time of the service and can then bill for three units. 

An occupational therapist is conducting a re-evaluation of an adolescent client. Insurers will reimburse the therapist bills the code 97004 and at the predetermined code rate. 

A physical therapist guides their client in 22 minutes of therapeutic exercise. Afterward, they supply a cold pack for inflammation. This therapist can bill one unit for 97110 and the untimed service code of 97101

Tips and tricks
  • Use one method of tracking time and stick to it. Many therapists use a Smartwatch for ease of accessibility while with patients.  Use a stopwatch app and start it as soon as you begin. Simple.  If there is a last-minute change, you'll know exactly when you started and finished. This is also a helpful tool for therapists who often go over their allotted time. 

  • Always know if the CPT code you are using is a 'timed' or 'service-based' code and if it can be used independently or must be bundled with another qualifying service. 

  • CPT codes change often!  They are reviewed and edited every year to ensure that they reflect the dynamic needs of health care. Stay up-to-date through your state or national professional association. 

  • An all-in-one electronic medical records system can minimize much of the uncertainty regarding documentation and reimbursement.  TheraPlatform provides an easy-to-use system that allows you to look up ICD-10 codes while you complete your documentation and auto-populates the code you select into documentation, billing, and claims. Sign up for a 30-day free trial. No credit card required. Cancel anytime. 


TheraPlatform is an all-in-one EHR, practice management and teletherapy tool that helps therapists spend less time on administrative tasks so they can spend more time helping clients. They also offer a 30-day free trial with no credit card required. Cancel anytime.

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CPT codes occupational therapy, 8 minute rule
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