Delegation to Staff is not Allowed. Can I Bill for Group Exercises if I Supervise?

by  Brandy Brimhall, CPC CPCO CMCO CPMA QCC
August 8th, 2017


My state does not allow me to delegate the supervision of therapeutic exercises (97110). I am the licensed chiropractor. If I provide the constant attendance myself, can I do it for a group of patients? If so, how do I document and bill for this?


Consider the following when billing 97150 Therapeutic procedure(s), group (2 or more individuals)

The therapeutic exercises should be documented just as thoroughly as 97110, including clear goals, details of the skilled services, functional loss and gains, etc.

The group can be up to four patients (per CMS), but check with individual payors.

Constant attendance (visual, verbal, and or manual contact) must be maintained throughout the service, but one-on-one contact is not required.

Patients may or may not be doing the same activity.

97150 is not time-based, therefore it is reported once per session per individual. Time should still be recorded, but the minimum 8-minute rule should not apply.

97150 would be reported for each individual receiving group therapy.

Supervising patients who are exercising independently or on exercise equipment is not a skilled service and may not be billable as group or individual therapeutic procedures.

The Medicare reimbursement for 97150 is about half of 97110, so consider that as you set your fee schedule.

If 97150 is used with additional therapeutic procedure code(s), there must be clear documentation to support that the group and the individual therapeutic procedures were performed during separate periods of activity. The 59 modifier would be used, and claims reviewers are likely to look closer at these kinds of claims.

Delegation to Staff is not Allowed. Can I Bill for Group Exercises if I Supervise?. (2017, August 8). Find-A-Code Articles. Retrieved from

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