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Over the years there has been much confusion over the coding of minutes when billing commercial payers.
APTA recommends billing be consistent to all payers. However, there is a distinct difference between Medicare’s 8-minute rule and the "passing the midpoint" standard in the Current Procedural Terminology (CPT) manual.
Many services that physical therapists and physical therapist assistants provide are described in terms of 15-minute units of service.
Medicare's guideline on counting minutes for timed codes in 15-minute units (often referred to as the "8-minute rule") is effective whenever more than one unit of these "timed" services is delivered. In essence, the Medicare billing guideline determines the number of units that can be billed based on the total number of minutes of timed services that were delivered. For example, at least 23 minutes of services must be delivered to bill two units of timed services; 38 minutes for three units; 53 minutes for four units; and so forth. CMS' Medicare Claims Processing Manual Chapter 5 Section 20 has more information.
On page xvii of the 2021 CPT manual there is a section entitled Time. In this section guidance for billing timed codes is provided indicating that the midline must be passed before a timed unit can be billed. For example, if the code represents a 15- minute unit then 7 minutes and 31 seconds of the service must be provided before the code can be billed. The CPT manual guidelines do not indicate a requirement to add total minutes to determine how many units can be billed, meaning a therapist could bill 1 unit of service every time the midpoint is passed for that unit of service.
It is critical to review payer policy to determine whether the payer follows the Medicare 8-minute rule or whether a provider may bill a unit every time the mid-point is passed.
At a minimum, APTA recommends that your employer's Policy and Procedure Manual explain how services are to be coded within your organization. If no guidance exists, you are encouraged to speak with the practice manager and or owner on putting a policy in place.
Even with this guidance from CPT on how to report services, APTA advises providers to always check payer policy for payment requirements. If your contract with a payer states, for example, that additional units may be billed after five minutes of services, that contract would take precedent over the standards outlined above.