Medicare Compliance & Reimbursement

Check out this reader question to clear up confusion on therapy services billing.

Question: I have a question regarding the following statement from CMS' therapy services billing scenarios Web page: www.cms.hhs.gov/TherapyServices/02_billing_ scenarios.asp#TopOfPage. In the section titled, "Billing CPT Codes: Not Permitted," the text reads, "In the same 15-minute (or other) time period, a therapist cannot bill any of the following pairs of CPT codes for outpatient therapy services provided to the same, or to different patients. Examples include: Any two CPT codes requiring either constant attendance or direct one-on-one patient contact ... (CPT codes 97032- 97542). For example: Any CPT code for a therapeutic procedure (eg. 97116-gait training) with any attended modality CPT code (eg. 97035-ultrasound)."

With this statement in mind, how would you bill this scenario: A Medicare patient receives ionto (CPT code 97033) to the shoulder (12 minutes) and  therapeutic exercise  (CPT code 97110) for 30 minutes. Total treatment time for this session is 42 minutes (3 units). Normally, I would charge two units of therapeutic exercise and one unit of ionto. However, the statement above indicates that this is not permitted. Would the correct charge be three units of therex (considering total treatment time is 42 minutes?)  I don't understand the rationale for not being able to bill therex with an attended modality.


Arizona subscriber
Answer: Billable time for the iontophoresis includes the patient education time and the iontophoresis set-up. The time that the unit is running is not billable, as you are not providing any skilled services during that time. Assuming that the 12 minutes you state is the patient education and set-up time that requires your skilled services, you would add those minutes to the 30 minutes of therapeutic exercise, which would give you a total of 42 minutes and allow you to bill three units.

What CMS meant by that question and answer is that during the same 15-minute period, you can't bill two CPT codes that require direct one-on-one contact with the patient. For example, if you treat a patient from 9:00 am to 9:15 am, it is impossible to bill for two units of a timed CPT code, such as gait training and therapeutic exercise to the same or different patients. It is possible, however, to bill for a supervised modality and a one-on-one direct contact CPT code during the same 15-minute increment, as the supervised modality does not require direct one-on-one contact by the provider.