Timed vs Untimed Therapy CPT Codes: The Medicare Rules

Medicare runs two different unit systems side by side on the same claim. Timed codes are billed in 15-minute units keyed to the minutes actually spent in direct patient contact; untimed codes are billed as exactly one unit, regardless of how many minutes the service took. The Medicare Claims Processing Manual, Ch. 5, §20.2 states the untimed rule plainly: “the provider enters ‘1’ in the field labeled units,” and gives the example of a speech-language evaluation (92521), where “regardless of the number of minutes spent providing this service only one unit of service is appropriately billed on the same day.”

That distinction gets harder to apply once you layer Medicare’s Physician Fee Schedule (PFS) status codes on top of it. 97010 (hot or cold packs) sits on the 2026 therapy code list as an always-therapy service, yet its PFS status is B, bundled, so it is never paid separately. 97014 (unattended electrical stimulation) has PFS status I, not valid for Medicare purposes; Medicare uses G0283 instead. Neither fact appears in a plain timed/untimed list: CMS dropped that column from its own unit-limit chart, noting in the Medicare Claims Processing Manual, Ch. 5, §20.2.D that “this notation is not relevant to the number of units allowed per code.”

This post assembles that missing column from the code definitions themselves, and pairs it with the other three things a claim needs: the CMS PFS National Relative Value File, RVU26D, the 2026 Therapy Code List and Dispositions, and the Medicare Practitioner Services MUE table effective October 1, 2026. Current as of October 2026.

What is the difference between timed and untimed CPT codes?

An untimed code’s descriptor does not define a per-unit time interval. You document how long the service took (it still counts toward total treatment time), but the claim line always carries 1 unit, whether the service took 5 minutes or 50. A timed code’s descriptor defines a 15-minute interval, and the number of units billed is constrained by the actual minutes documented, following the unit chart and remainder rules in the Medicare Claims Processing Manual, Ch. 5, §20.2.B and §20.2.C. CMS’s own example of a timed code: “60 minutes of occupational therapy, e.g., HCPCS ‘timed’ code 97530 which is defined in 15 minute units… report 4 units of 97530.”

CMS’s billing examples page for the CQ/CO modifiers gives its own summary of the untimed category: “one unit is billed for all untimed codes including evaluations, reevaluations, supervised modalities, group therapy, and 2 RTM codes (98975 and 98980).” Supervised modalities (CPT 97010-97028) get an allowance no other physical medicine service gets: per the Medicare NCCI Policy Manual, Chapter XI, §P.2, providers “shall not report more than one physical medicine and rehabilitation therapy service for the same fifteen-minute time period,” with one exception, a “supervised modality,” which “may be reported for the same fifteen-minute time period as other therapy services.” A hot pack running alongside manual therapy is not a documentation conflict; every other timed procedure needs its own clock. See the NCCI edits post for more on how these PTP edits work.

The treatment note has to carry both totals side by side. Per the Medicare Benefit Policy Manual, Ch. 15, §220.3.E, the note must show “total timed code treatment minutes and total treatment time in minutes,” where “total treatment time includes the minutes for timed code treatment and untimed code treatment” but excludes non-billable time like rest periods. The manual adds that “the billing and the total timed code treatment minutes must be consistent,” which is the line auditors check first.

Which PT, OT, and SLP codes are timed and which are untimed?

The tables below combine four CMS sources: the code descriptors themselves; PFS status from RVU26D (October 2026 release); the always-therapy, sometimes-therapy, and bundled dispositions from the 2026 Therapy Code List; and per-day unit ceilings from the Practitioner Services MUE table effective October 1, 2026. An MUE of 0 means no units are ever payable. Per the NCCI Policy Manual, Chapter I, MAI 2 is an absolute per-day edit with no override, and MAI 3 is a per-day clinical benchmark a contractor may bypass with medical-review evidence. “MPPR” below means the code carries MPPR indicator 5 in RVU26D and appears on the CY 2026 MPPR rate file; see the MPPR post for the reduction math.

Supervised modalities and unattended e-stim (all untimed, one unit per date of service)

Constant-attendance modalities and therapeutic procedures (mostly timed)

Evaluations, tests, SLP, and RTM

For the full RTM code set and how the treatment-management minutes work across a calendar month, see the RTM billing post.

Is 97010 billable to Medicare?

97010 (hot or cold packs) is on the 2026 Therapy Code List under two dispositions at once: disposition 3 (bundled) and disposition 5 (always therapy). Disposition 3 controls the payment outcome: “regardless of whether they are billed alone or in conjunction with another therapy code, never make payment separately for these codes. If billed alone, these codes shall be denied,” with remittance group code CO and reason code 97 (“payment is included in the allowance for another service/procedure”). In RVU26D, 97010 carries PFS status B, and the file is explicit that for status B, “if RVUs are shown, they are not used for Medicare payment.” Its practitioner MUE, effective October 1, 2026, is 0.

Document it if it’s part of the plan of care, since disposition 5 still requires the GP/GO/GN modifier when reported, but don’t expect payment. It rides along with the day’s other services and never produces revenue on its own.

97014 vs G0283: which one does Medicare pay?

97014 (unattended electrical stimulation) carries PFS status I in RVU26D: “not valid for Medicare purposes. Medicare uses another code for reporting of, and payment for, these services.” It does not appear on the 2026 Therapy Code List at all, and its MUE is 0.

The code Medicare uses instead is G0283, described in the HCPCS Level II file as “electrical stimulation (unattended), to one or more areas for indication(s) other than wound care, as part of a therapy plan of care.” G0283 has PFS status A, is on the always-therapy list, carries the MPPR indicator, and has an MUE of 1. If the indication is one of the specific chronic ulcers CMS lists (stage III/IV pressure, arterial, diabetic, or venous stasis ulcers not healing after 30 days of conventional care), the correct unattended e-stim code is G0281 instead; G0329 covers electromagnetic therapy for the same ulcer population. Per the NCCI Policy Manual, Chapter XI, G0283 is not separately reportable with CPT 92526 when the electrical stimulation is part of a swallowing treatment procedure.

Do untimed codes count toward the 8-minute rule?

No. The Medicare Claims Processing Manual, Ch. 5, §20.2.C is explicit that “the total minutes of active treatment counted for all 15 minute timed codes includes all direct treatment time for the timed codes,” and separately notes that “total treatment minutes, including minutes spent providing services represented by untimed codes, are also documented.” Untimed minutes go into total treatment time on the note. They never enter the timed-minute pool that the 8-minute rule uses to determine how many timed units a day supports, and they never take a unit count of their own beyond the flat 1.

That separation is exactly what trips people up on RTM. The treatment-management codes (98979, 98980, 98981) have minutes in their descriptors, 10 and 20 minutes, but those minutes are tallied over a calendar month, not a single visit, and they never enter a visit’s timed-minute total alongside 97110 or 97140.

Does the MPPR apply to untimed codes?

Yes, for untimed codes on the always-therapy list that aren’t bundled, add-on, or contractor-priced. The Medicare Claims Processing Manual, Ch. 5, §10.7 states the MPPR “applies to multiple units as well as multiple procedures”: it ranks a day’s services by practice-expense RVU, pays the highest-PE line in full, and cuts the practice-expense portion of every other line by 50 percent. The supervised modalities, G0281/G0283/G0329, the evaluation and re-evaluation codes, and 97150 all carry MPPR indicator 5 in RVU26D and appear on the CY 2026 MPPR rate file. An untimed modality is almost never the day’s highest-PE line, so it’s almost always the line that takes the cut. RTM and other sometimes-therapy codes (97129, 97130, 97545, 97546, 97550-97552, 96105) carry MPPR indicator 0 and aren’t reduced at all. 97010 is excluded on separate grounds: it’s bundled, so there’s no separate payment to reduce. See the MPPR post for the full math.

A worked visit: two untimed and three timed services

Here is one established Medicare Part B PT visit, one date of service, with both kinds of code on the same note.

Total timed-code treatment minutes: 23 + 15 + 10 = 48 minutes. Total treatment time: 48 + 10 + 12 = 70 minutes. Both numbers belong on the note, per the Medicare Benefit Policy Manual, Ch. 15, §220.3.E.

Forty-eight timed minutes falls in the range that supports 3 units (38 to 52 minutes, per §20.2.C; see the 8-minute rule post for the full unit chart). Assigning those three units: 97110’s 23 minutes give one full unit with 8 left over; 97140’s 15 minutes give one full unit with 0 left over; 97530’s 10 minutes don’t reach a full unit, leaving a remainder of 10. Two full units are assigned first (97110, 97140); the third goes to the larger remainder, and 97530’s 10 beats 97110’s 8.

The untimed codes don’t compete for that allocation at all. G0283 bills its flat 1 unit regardless of its 12 minutes; 97010 would too, except it’s never paid.

These dollar figures are national, unadjusted illustrations built from the total RVUs in RVU26D at the CY 2026 conversion factor of $33.4009 with GPCIs of 1.0, not CMS-published payment amounts. Before the MPPR, the four paid lines total $104.54. Ranking by practice-expense RVU puts 97530 highest, paid in full; 97110, 97140, and G0283 each have their PE component cut 50 percent, bringing the visit to $88.01, a reduction of $16.53. See the MPPR post for the per-line math. G0283 takes the hardest proportional hit: its reduced line is $3.17 lower, about 25 percent of its own allowed amount, because half of G0283’s relative value (0.19 of 0.38 RVUs) sits in the practice-expense component.

One more thing this visit shows: if the 12 minutes of unattended e-stim had been mistakenly folded into the timed-minute total (48 + 12 = 60 minutes, which would suggest 4 units), the claim would carry a fourth timed unit the documentation cannot support. §20.2.C constrains timed units to timed minutes only; untimed minutes never add to that pool, no matter how long the untimed service ran.

What the documentation has to support

The note requirements aren’t specific to timed or untimed codes alone; the Medicare Benefit Policy Manual, Ch. 15, §220.3.E requires “identification of each specific intervention/modality provided and billed, for both timed and untimed codes, in language that can be compared with the billing on the claim to verify correct coding,” including “each service… represented by a timed code, regardless of whether or not it is billed, because the unbilled timed services may impact the billing.” Per-intervention minutes are voluntary, but “the billing and the total timed code treatment minutes must be consistent.” See the documentation requirements post for how these notes hold up under review.

When a PTA or OTA is involved, an untimed code gets the same 10 percent de minimis test as a timed one, just applied to the whole service instead of per unit. CMS’s own example: an OTA and OT each independently furnish 20 minutes of group therapy (97150), 40 minutes total, and the single unit takes the CO modifier because the OTA’s share is 50 percent, well over the 10 percent standard. See the CQ/CO modifier post for the full de minimis mechanics.

Quick answers to the edge cases

Does the time on an untimed code count toward the 8-minute rule? No. It goes into total treatment time only, never into the timed-minute pool that determines unit count.

Can I bill 97010 to Medicare? It’s on the therapy list as always-therapy, but its PFS status is bundled (B). It’s never paid separately, its MUE is 0, and a line billed alone is denied CO 97. Document it; don’t expect payment.

What replaces 97014 for Medicare? G0283 for most indications, or G0281 for the specific chronic ulcers CMS lists. 97014 has an MUE of 0 and isn’t on the 2026 therapy code list.

Can I bill two units of 97012 if I did traction twice in one visit? No. Its MUE is 1 per date of service (MAI 3), and as an untimed code it’s always entered as 1 unit regardless of minutes.

Does an eval’s “typically 30 minutes” make it a timed code? No. Evaluations and re-evaluations are untimed: one unit, MUE 1 with MAI 2 (an absolute per-day edit), and no more than one PT or OT eval per date of service.

Are two supervised modalities at the same time both billable? The NCCI manual allows a supervised modality (97010-97028) to be reported for the same 15-minute period as other therapy services; each still bills as its own 1 unit.

Do untimed codes take the MPPR? Yes, if they’re always-therapy and not bundled or contractor-priced: supervised modalities, G0281/G0283/G0329, the evaluation codes, and 97150 all carry the MPPR indicator. RTM codes and other sometimes-therapy codes do not.

How does the PTA/OTA 10 percent standard apply to an untimed code? It’s applied to the whole service rather than per unit; see the CQ/CO modifier post.

Are 97545 and 97546 ever billed to Medicare patients? Rarely. They’re timed, but in 2-hour (97545) and 1-hour (97546) intervals rather than 15 minutes, carry restricted-coverage PFS status, and aren’t on the 2026 therapy code list. CMS does not expect to see them reported for Medicare patients except in very unusual circumstances.

Do the RTM management codes’ 10- and 20-minute descriptors work like the 8-minute rule? No. Those minutes (98979, 98980, 98981) are tracked per calendar month, not per visit, and never enter a single visit’s timed-minute total.

Untimed codes, bundled codes, and per-day MUE ceilings are exactly the kind of rules that are easy to get right once and forget the next time a payer or a code list changes. PrismEHR lets organizations define their own billing rules, including minute and unit restrictions by code, enforced at the point of documentation and reinforced again at claim creation, and it does not prefill CPT units from the prior visit; units default to zero every time. For Medicare patients, PrismEHR sums timed units across codes as you document and calculates and restricts units under the 8-minute rule automatically. See how it fits physical therapy practices.