Medicare ADVISOR Q&A

Medicare Advisor

Question: Can one bill Medicare for a home exercise program under CPT code 97353?

Answer: It all depends. With any of the CPT codes, you should bill what you do as compared to the definitions for the CPT code. Because there is no separate code for a home exercise program, the time it takes to teach the exercises falls under what specifically you are doing and what you are documenting.

If you are teaching exercise for strengthening and increasing ROM, you would bill CPT code 97110. If you are teaching exercises that include dynamic activities, you would bill CPT code 97530. If you are instructing and training the patient in ADL activities and compensatory strategies you would bill 97353. We use a phrase in our seminars on documentation that is apropos here: "Document what you do and then bill what you document!"

Question: Is it required to log in the exact time in/time out for treatment with Medicare Part A patients in a SNF or can you just log in the total treatment time? Also, in multiple articles you have addressed group vs. concurrent therapy. Please clarify how you would bill three patients working on different functional tasks at the same time under Medicare Part A in a SNF.

Answer: For the first question, Medicare regulations do not require the time in/time out (when patient starts treatment and when they finish the last activity) to be documented. Under Part A, Medicare is paying for the time the beneficiary is receiving services and the rate is established during the observation period.

Most of the time, on medical review, the reviewer will look at the patient chart to see if the patient could have tolerated the treatment time identified in the medical record. However, as with everything to do with Medicare, you need to check to see if your fiscal intermediary requires additional documentation beyond Medicare requirements as far as documenting time in/time out.

As to the second question, under Part A, Medicare only discriminates between group and individual treatment. Concurrent therapy or dovetailing has been addressed multiple times by Medicare for Part A.  In the last update to the Final Rule, CMS looked to the professional associations for guidance in defining concurrent therapy.

Under the current regulation, you would bill each of the patients the total time spent in therapy. However, in counting those minutes during the observation period to create the RUG level, you need to determine if all the time you accounted for in providing treatment for these patients skilled. If not, then you need to modify the total treatment time to reflect skilled time vs. non-skilled time.

Question: When a patient with Medicare is evaluated in an outpatient clinic and a HCFA 700 form is completed, is it appropriate to fax the form to the physician instead of mailing the form?  The turn-around time is greatly improved during this process and physicians seem to prefer this mode versus mailing the 700, not to mention the added cost for postage and envelopes. 

Answer: The plan of treatment has to be sent to the physician or non-physician practitioner to review and certify need. The method that the provider communicates with the physician is left entirely up to the practitioner, Medicare has no regulation. The plan of treatment can be mailed, faxed or delivered electronically. You should look at the new regulations covering Part B. The 700 and 701 no longer exist as far as CMS is concerned and the new therapy regulations certainly make its use no longer appropriate.

If you have a question about Medicare reimbursement you would like the authors to address, send your question and contact information to Medicare Advisor, c/o Lisa Lombardo, ADVANCE for PTs & PTAs, 2900 Horizon Dr., King of Prussia, PA 19406; fax 610-278-8623;

Pauline Franko is owner and principal lecturer for Encompass Consulting & Education, LLC, a rehabilitation consulting and education company producing "Direction on Demand" (See our ad in the current issue of Advance for all our seminars); Danna Mullins is an associate and lecturer. You may contact the authors through the Encompass website at



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