Billing and Documenting for Therapeutic Exercises versus Therapeutic Activities

by  Dr. Evan M. Gwilliam, DC, MBA, QCC, CPC, CCPC, CPMA, CPCO, AAPC Fellow, Clinical Director
July 13th, 2022

Chiropractors treat, among other things, issues with the musculoskeletal system.  Active therapeutic procedures are accepted as effective ways to treat many common conditions and therefore can be billed and generate revenue for a clinic.  Two common CPT codes that might be used in a chiropractic setting include: 

97110 - Therapeutic procedure, 1 or more areas, each 15 minutes; therapeutic exercises to develop strength and endurance, range of motion and flexibility

97530 -Therapeutic activities, direct (one-on-one) patient contact (use of dynamic activities to improve functional performance), each 15 minutes

Though Medicare does not reimburse chiropractors for either of these codes, understanding their policies in relation to these services is wise since many private payers follow Medicare standards.  Medicare states that, "Therapeutic procedures are procedures that attempt to reduce impairments and restore function through the application of clinical skills and/or services."  So, first and foremost, in order for either of these services to be justified, there must be some sort of functional loss and the service must provide functional gains, requiring the skills of someone who knows what they are doing.

There are several other things that these codes have in common:

Although Medicare does not pay chiropractors for 97110, we can learn from their policies.  LCD L35036 tells us that:

Therapeutic exercise is designed to develop strength and endurance, range of motion, and flexibility and may include: active, active-assisted or passive (e.g., treadmill, isokinetic exercise, lumbar stabilization, stretching, strengthening) exercises. The exercise may be medically reasonable and necessary for a loss or restriction of joint motion, strength, functional capacity or mobility that has resulted from a specific disease or injury. It is considered medically reasonable and necessary if an exercise is taught to a patient and performed by a skilled therapist for the purpose of restoring functional strength, range of motion, endurance training, and flexibility. Documentation must show objective loss of joint motion, strength or mobility (e.g., degrees of motion, strength grades, levels of assistance). This therapeutic procedure is measured in 15-minute units with therapy sessions frequently consisting of several units.

Many therapeutic exercises may require the unique skills of a therapist to evaluate the patient’s abilities, design the program, and instruct the patient or caregiver in safe completion of the special technique. However, after the teaching has been successfully completed, repetition of the exercise, and monitoring for the completion of the task, in the absence of additional skilled care, is non-covered.”

The takeaway is that if the documentation shows that the patient has a loss of strength, range of motion, endurance, or flexibility, then 97110 can be justified.  However, the treatment goals for exercise should clearly document anticipated improvement in those same parameters.

If we look at CMS policies (see LCD L35036) regarding 97530 we learn that: 

“This procedure involves using functional activities (e.g., bending, lifting, carrying, reaching, catching and overhead activities) to improve functional performance.

The activities are usually directed at a loss or restriction of mobility, strength, balance or coordination. They require the professional skills of a qualified professional and are designed to address a specific functional need of the patient. These dynamic activities must be part of an active treatment plan and directed at a specific outcome.”

For 97530, the record needs to document some sort of loss of the ability to perform activities and explain how the procedure restores that loss.  The activity description would often include a verb ending in “ing”.  The patient’s condition should be such that he/she is unable to perform therapeutic activities except under the direct supervision of a physician or physical therapist.  Related diagnoses might include:

97110 focuses on one parameter, such as strength.  97530 takes things to the next level and focuses on some activity that may be dependent on multiple parameters in addition to strength.  For example, shoulder strengthening exercises might be billed as 97110, but tossing a ball against a trampoline and catching it, which focuses on multiple parameters, would be 97530.

In a clinical setting, a patient may begin care with stretches to improve ROM (billed as 97110).  After four weeks of stretches, and the goals are reached, perhaps care starts to focus on strengthening exercises due to findings of weakness in the initial exam.  This would also be billed as 97110.  Once the strength goals are reached (maybe after another four weeks), the new procedure could focus more on the dynamic activity of lifting boxes, which would then be billed as 97530

When deciding which code is more appropriate, make sure the documentation includes objective findings that line up with the official code description, and goals that focus on the parameters that are outlined by the code and the payer and CPT guidelines above.

Disclaimer: The above article is the opinion of the author(s) and should not be interpreted by providers/payers as official guidance. For any questions about the content of this article, please contact the author(s).

About the Author: Dr. Evan Gwilliam is a certified coder, auditor, and compliance officer.  He trains clinicians on how to create rock solid records with PayDC, which is a dynamic cloud based EHR software.  If you would like to learn more, email him at

Billing and Documenting for Therapeutic Exercises versus Therapeutic Activities. (2022, July 13). Find-A-Code Articles. Retrieved from

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