CPT Code 97010: Hot and Cold Pack Billing for Chiropractors in 2026

CPT code 97010 is a supervised, untimed modality code that describes the application of a hot or cold pack to one or more body areas for therapeutic purposes in physical medicine and rehabilitation settings. Medicare considers 97010 a bundled service under status indicator T, meaning it is not separately reimbursable when any other payable service is billed on the same date, though many commercial payers, workers’ compensation carriers, and personal injury plans do reimburse it as a standalone line item.

• Medicare bundling status. CMS assigns 97010 a status indicator of T, so it is always absorbed into the CMT codes (98940-98942) on chiropractic Medicare claims and will never generate separate payment.
• Untimed, one unit per visit. 97010 is billed as a single unit per encounter regardless of application duration or the number of body areas treated with hot or cold packs.
• Documentation is the gatekeeper. Even for payers that reimburse 97010 separately, the claim requires documentation of the specific body area, modality type, clinical rationale, and patient response to survive audit review.

Table of Contents

• What Is CPT Code 97010?
• When Should Chiropractors Bill 97010?
• Why Does Medicare Bundle CPT 97010?
• How Do Commercial Payers Handle 97010?
• What Documentation Does 97010 Require?
• How Does 97010 Differ From Other Modality Codes?
• What Are Common 97010 Billing Mistakes in Chiropractic?
• Frequently Asked Questions

What Is CPT Code 97010?

CPT code 97010 is the Current Procedural Terminology code that describes the application of a hot or cold pack to one or more areas of the body as a supervised therapeutic modality. This code falls under the Physical Medicine and Rehabilitation section of the CPT code set maintained by the American Medical Association (AMA). In chiropractic settings, providers use hot packs (moist heat) or cold packs (cryotherapy) to reduce pain, decrease inflammation, relax muscle tension, and promote tissue healing before or after spinal manipulation.

There are three characteristics of 97010 that every chiropractic biller needs to understand from the start.

• Supervised modality. CPT 97010 is classified as a supervised modality, which means it does not require direct one-on-one patient contact by the provider. An appropriately trained chiropractic assistant (CA) can apply the hot or cold pack while the chiropractor remains in the office but does not need to be present in the treatment room during the application.
• Untimed code. Unlike therapeutic procedure codes such as 97110 or 97140, CPT 97010 is an untimed code. You bill one unit regardless of how long the patient receives heat or ice therapy. Whether the application lasts 10 minutes or 20 minutes, you report a single unit of 97010.
• One unit per encounter. You can only bill 97010 once per visit even if you apply hot or cold packs to multiple body areas during the same session. Applying a hot pack to the cervical spine and an ice pack to the lumbar spine in one visit still results in one unit of 97010.

The most common issue we see providers run into with this code is the assumption that 97010 works like timed therapeutic codes. It does not. Understanding these three foundational rules before submitting any 97010 claim prevents the majority of billing errors that lead to denials.

When Should Chiropractors Bill 97010?

Chiropractors should bill CPT 97010 when they apply moist heat or cryotherapy to a patient as a distinct, medically necessary service that is part of the documented treatment plan. The clinical scenarios where 97010 is appropriate in a chiropractic setting typically involve preparing tissue for spinal manipulation or managing post-adjustment inflammation and soreness.

Appropriate clinical scenarios for billing 97010 in chiropractic care include:

• Applying moist heat to the thoracic and lumbar regions before a CMT session to relax paravertebral musculature and improve range of motion for adjustment
• Using cryotherapy after spinal manipulation to reduce acute inflammatory response in patients presenting with acute subluxation and associated muscle spasm
• Applying a cold pack to a cervical region following an extremity adjustment where the patient presents with radiculopathy and localized swelling
• Delivering moist heat to a patient with chronic myofascial pain as part of a multi-visit treatment plan that documents measurable functional goals
• Using ice application on a lumbar region following therapeutic exercise (97110) when the exercise produced an expected inflammatory response

The key consideration before billing 97010 is whether the payer will reimburse it. Providers often come to us after accumulating denials on 97010 claims because they billed Medicare for this code without realizing it is bundled. Before you apply and bill for 97010, verify the patient’s payer. If the patient carries Medicare as their primary insurer, 97010 is not separately billable. This single verification step eliminates the most common denial trigger for this code.

For commercial payers that do reimburse 97010, the service must be documented as medically necessary with a clear clinical rationale. A note that simply states “applied hot pack” without connecting it to a specific diagnosis, treatment goal, and functional outcome is not sufficient to support the claim. If you are unfamiliar with how the CMT codes interact with adjunctive modalities, our guide to CPT code 98940 covers the spinal manipulation billing foundation that 97010 builds on.

Why Does Medicare Bundle CPT 97010?

Medicare assigns CPT 97010 a status indicator of “T” on the National Physician Fee Schedule (NPFS), which means it is a bundled service. According to CMS policy, codes with a T status indicator have relative value units (RVUs) and calculated payment amounts, but those amounts are only paid when no other services payable under the physician fee schedule are billed on the same date by the same provider. When any other covered service is billed alongside 97010 on the same date, the 97010 reimbursement is absorbed into the primary service.

For chiropractors, this means 97010 is always bundled into the CMT codes (98940, 98941, or 98942) when billed to Medicare. Since virtually every chiropractic encounter includes a spinal manipulation, there is almost no scenario where a chiropractor can collect separate Medicare payment for hot or cold pack application.

The CMS Outpatient Physical and Occupational Therapy Services billing article (A56566) states this directly: code 97010 is bundled, it may be bundled with any therapy code, and regardless of whether it is billed alone or alongside another therapy code, it is never paid separately under Medicare. If billed alone, the claim is denied.

This policy applies specifically to Medicare. It does not apply universally to all payers. However, many commercial payers follow CMS guidelines as their baseline, which means the bundling issue extends beyond Medicare patients in many practices. For the latest on how Medicare reimbursement rates are shifting for chiropractic services, see our breakdown of 2027 chiropractic Medicare payment changes.

In our experience matching providers with billing partners, one recurring pattern is practices billing 97010 to Medicare for months before discovering every claim was denied or bundled at zero reimbursement. A billing company that understands chiropractic-specific Medicare rules catches this on day one and prevents the revenue leakage before it starts.

It is worth noting the American Chiropractic Association (ACA) position on this issue. The ACA has stated that the work of hot and cold packs as described by CPT code 97010 is not included in the CMT codes 98940-98943 when moist heat or cryotherapy is medically necessary for a specific physiological effect. Despite this position, CMS has not changed the bundling status, and Medicare continues to treat 97010 as a non-separately-payable service for chiropractic claims.

How Do Commercial Payers Handle 97010?

Commercial payer reimbursement for CPT 97010 varies significantly by insurer, plan type, and state. Unlike Medicare’s blanket bundling policy, many commercial payers will reimburse 97010 as a separate line item when it is properly documented and billed with the correct modifiers. However, the reimbursement landscape is inconsistent enough that chiropractors should verify coverage on a payer-by-payer basis before assuming any commercial plan covers this code.

The table below summarizes general 97010 reimbursement patterns across major payer categories. Actual reimbursement depends on your specific contract, locality, and plan type.

Across the billing companies we vet, a recurring pattern is that workers’ compensation and personal injury claims reimburse 97010 at significantly higher rates than commercial health insurance. If your practice sees a high volume of auto accident or workplace injury patients, 97010 can represent meaningful revenue when documented correctly.

For commercial claims where 97010 is covered, use modifier GP (services delivered under an outpatient physical therapy plan of care) when billing under a physical therapy plan. If 97010 is delivered as a distinct service separate from other modalities on the same date, modifier 59 or the more specific X-modifiers (XE, XS, XU) may be needed to prevent automatic bundling by the payer’s claims processing system.

One question we hear constantly from practice managers is whether they should stop billing 97010 entirely. The answer depends on your payer mix. If 80% of your patients carry Medicare, the administrative cost of billing 97010 likely exceeds any potential reimbursement. If your practice handles a significant volume of commercial, workers’ comp, or PI cases, 97010 is worth billing correctly on every eligible claim.

What Documentation Does 97010 Require?

Documentation requirements for CPT 97010 follow the same medical necessity standard as any other chiropractic service, but the specific elements that must appear in the clinical note are often overlooked because providers view hot and cold pack application as routine. That perception is exactly what triggers post-payment audit findings and retroactive recoupments.

Every 97010 claim must be supported by documentation that includes all of the following elements:

• The specific body area treated. Identify the anatomical site where the hot or cold pack was applied. “Applied hot pack” is not sufficient. “Applied moist heat to the bilateral thoracic paravertebral musculature” passes audit review.
• The type of thermal modality used. State whether the application was moist heat, dry heat, ice pack, cold compression, or another form of cryotherapy. The note must distinguish between hot and cold.
• The clinical rationale. Connect the modality to the patient’s diagnosis, symptoms, and treatment plan. Document why the application was medically necessary for this specific patient at this specific visit.
• The physiological objective. State the intended therapeutic effect, whether that is reducing muscle spasm, decreasing acute inflammation, improving tissue extensibility before manipulation, or reducing post-adjustment soreness.
• Duration of application. Although 97010 is untimed for billing purposes, CMS and most commercial payers still require you to document how long the modality was applied. Standard application times range from 10 to 20 minutes.
• The patient’s response. Note the patient’s subjective and objective response to the treatment. Did the heat reduce reported pain? Did the ice decrease visible swelling? Did range of motion improve after application?

The documentation also needs to tie back to your overall treatment plan. A standalone 97010 service without a broader context of what you are treating and how the thermal modality fits into the progression of care is a red flag for any auditor.

Providers who work with experienced chiropractic billing companies consistently produce cleaner documentation because the billing team flags incomplete notes before submission rather than after denial. This feedback loop between documentation and billing is one of the highest-impact areas where specialized billing support reduces claim rejections.

How Does 97010 Differ From Other Modality Codes?

CPT 97010 is one of several supervised and constant attendance modality codes in the Physical Medicine and Rehabilitation section of the CPT code set. Understanding where 97010 sits in relation to other commonly billed modality codes helps chiropractors select the correct code for the service delivered and avoid coding errors that lead to denials or compliance issues.

The critical distinction between 97010 and codes like 97012 or 97014 is Medicare payment status. While all three are supervised modalities, 97012 (mechanical traction) and 97014 (electrical stimulation) are separately payable under Medicare, but 97010 is not. This means practices that routinely apply heat or ice alongside traction or electrical stimulation need to understand that only the traction and e-stim components generate separate Medicare reimbursement.

For electrical stimulation billed to Medicare, note that you must use HCPCS code G0283 instead of CPT 97014. Medicare does not accept 97014 directly. This is another area where chiropractic-specific billing knowledge prevents unnecessary denials. Chiropractors navigating same-day billing rules should also review the 2027 same-day E/M cut for chiropractic to stay current on related policy changes.

When billing 97010 alongside timed codes like 97110 or 97035 on commercial claims, remember that 97010 is untimed and does not count toward your total timed minutes for the 8-minute rule calculation. Only timed codes contribute to the 8-minute rule. The minutes spent applying hot or cold packs under 97010 exist outside that calculation entirely.

What Are Common 97010 Billing Mistakes in Chiropractic?

Billing errors on CPT 97010 are disproportionately common relative to how simple the service appears. The code describes applying a hot or cold pack, but the billing rules around it create traps that catch even experienced chiropractic billers. Here are the mistakes that generate the most denials, audits, and lost revenue.

• Billing 97010 to Medicare and expecting separate payment. This is the single most frequent error. Medicare bundles 97010 under status indicator T. It will never pay separately when any other service is billed on the same date. If billed alone, it is denied outright. Submitting 97010 to Medicare is wasted administrative effort that increases your denial rate metrics without any reimbursement upside.
• Billing multiple units of 97010 per encounter. Some practices bill two units when they apply heat to one region and ice to another during the same visit. This is incorrect. CPT 97010 allows one unit per encounter regardless of how many areas receive hot or cold pack application or how many different thermal modalities are used.
• Failing to verify payer-specific bundling policies. Even among commercial payers, some follow the CMS T-status bundling logic. UnitedHealthcare, for example, explicitly states in its reimbursement policies that codes with a T status indicator are bundled into services with an A or R status indicator on the same date, and modifier overrides will not prevent this bundling. Not all commercial plans follow this rule, but assuming they all reimburse separately is a costly mistake.
• Insufficient documentation. Writing “hot pack applied x15 min” without identifying the body area, the diagnosis it supports, the clinical rationale, or the patient response. This documentation gap is the leading cause of post-payment recoupments on 97010 claims that initially paid.
• Confusing 97010 with 97014 or 97032. Electrical stimulation and hot/cold packs are different modalities with different codes, different reimbursement rules, and different supervision requirements. Applying the wrong code to the wrong service is a compliance violation, not just a billing error.
• Not tracking denial patterns by payer. Without tracking which payers deny 97010 and which reimburse it, practices continue submitting claims that will never pay. A quarterly review of 97010 denial rates by payer takes 30 minutes and can redirect billing effort toward claims that actually generate revenue.

Frequently Asked Questions