CPT Code 97110 for Chiropractors: Billing, Modifiers, and 2026 Reimbursement

What Is CPT Code 97110 for Chiropractors?

CPT code 97110 is a timed physical medicine procedure that bills therapeutic exercise to improve strength, endurance, range of motion, and flexibility, reported in 15-minute units of direct one-on-one care. In a chiropractic office it is a common companion to spinal manipulation, but Medicare does not cover 97110 when a chiropractor performs it, so whether you get paid depends almost entirely on the payer and your state scope of practice.

• Medicare coverage: Medicare pays chiropractors only for spinal manipulation (CMT codes 98940 to 98942). Therapeutic exercise under 97110 is statutorily excluded and must carry modifier GY when submitted to Medicare.
• Commercial and Medicaid: Many commercial plans and some state Medicaid programs do reimburse 97110 for chiropractors when the notes show skilled, time-based care. Coverage and visit limits vary by plan and state.
• Modifiers that matter: Append modifier GP because the service runs under a therapy plan of care, and add modifier 59 (or the correct X subset) when 97110 is performed in the same visit as an adjustment.

For chiropractic practices, 97110 is one of the most misbilled codes on the fee schedule. The exercise itself is routine. The billing is not. The same code a physical therapist bills without a second thought can trigger an automatic denial, a bundling edit, or an audit flag in a chiropractic office, because the rules change based on who performs the service and who is paying for it. Here is exactly how to handle 97110 in 2026 so the claims that should pay actually pay.

Does Medicare Cover CPT 97110 for Chiropractors?

No. Medicare covers only one service when a chiropractor performs it: manual manipulation of the spine to correct a subluxation, billed with CMT codes 98940, 98941, or 98942. Therapeutic exercise under 97110 is statutorily excluded from the Medicare chiropractic benefit, so a chiropractor cannot be reimbursed by Medicare for it.

This is not a documentation problem you can fix with better notes. It is a statutory limit set in the CMS Medicare Benefit Policy Manual, which restricts chiropractic coverage to hands-on spinal manipulation. Everything else a chiropractor commonly does, including exams, X-rays, extraspinal manipulation (98943), and therapy codes like 97110, 97112, and 97140, falls outside that benefit. When you submit 97110 to Medicare, you append modifier GY to flag a statutorily excluded service. The claim will deny, which is the point: the denial lets a secondary payer adjudicate and documents that the patient is financially responsible. If the service also runs under a therapy plan of care, add modifier GP so the line routes through the correct therapy edits. Billing 97110 to Medicare without GY, or trying to make it look covered, is the kind of pattern that draws probe reviews.

Which Payers Cover CPT 97110 for Chiropractors?

Coverage splits sharply by payer. Medicare excludes it, but the commercial and cash side is where 97110 becomes a legitimate revenue line for chiropractic practices, provided your state scope of practice allows you to deliver therapeutic exercise and your notes prove skilled, time-based care.

The practical takeaway: never assume the rule for one payer applies to the next. Run 97110 through each payer’s policy before the first claim, confirm your state board permits therapeutic exercise within the chiropractic scope, and remember that with some commercial plans a chiropractor’s therapy visits count against the patient’s annual physical therapy visit cap even though the patient never saw a physical therapist.

How Do the 97110 Modifiers Work in Chiropractic?

Modifier selection is where most chiropractic 97110 claims live or die. Industry billing analyses attribute roughly 31% of chiropractic denials to modifier errors alone, and 97110 sits right in the middle of that risk. Three modifiers do the heavy lifting, and one belongs somewhere else entirely.

• Modifier 59 (or the X subset, usually XU): Append to 97110 when it is performed in the same visit as a spinal manipulation (98940 to 98942) or manual therapy (97140). It tells the payer the exercise was a distinct, separately identifiable service, not a component of the adjustment. Without it, NCCI edits bundle 97110 into the manipulation and the line is lost. Back it with notes showing separate time, technique, and clinical goal.
• Modifier GP: Append when 97110 is delivered under a therapy plan of care. It marks the service as an outpatient physical medicine code and routes it through therapy edits. GP describes the type of service, not the type of provider, so it applies even when a chiropractor performs it.
• Modifier GY (Medicare only): Append when billing 97110 to Medicare, because the service is statutorily excluded when a chiropractor performs it. This forces the denial that lets a secondary pay and confirms patient liability.
• Modifier AT (belongs on the adjustment, not on 97110): AT signals active, corrective care and goes on the CMT codes 98940 to 98942. Adding it to a therapy code like 97110 is a common and avoidable error.

How Many Units of CPT 97110 Can You Bill?

CPT 97110 is a timed code billed in 15-minute units, and Medicare’s 8-minute rule sets how minutes convert to units. You need at least 8 minutes of direct, one-on-one therapeutic exercise to bill a single unit. From there, each additional block of roughly 15 minutes adds a unit, based on the total timed minutes in the session.

Two rules trip people up. First, only direct one-on-one minutes count; time the patient spends exercising unsupervised cannot be billed. Second, when you provide more than one timed code in a visit, you total all timed minutes and then allocate units, rather than counting each code in isolation. Reading the clock honestly is not optional. Time inflation on 97110 is one of the clearest audit triggers there is.

What Documentation Supports CPT 97110?

Payers reimburse 97110 when the record proves the exercise required your skill and moved the patient toward a functional goal. Cloned notes and vague entries are the fastest route to a denial. Build every 97110 note to do the following:

1. Record the exact exercises performed, including sets, repetitions, resistance, and body region.
2. Name the specific impairment being treated, such as reduced lumbar range of motion or a measurable strength deficit.
3. Tie the exercise to a functional goal, for example returning to lifting, prolonged sitting, or overhead reach.
4. Show measurable progress from visit to visit, not a copy of the prior note.
5. Log the exact one-on-one minutes spent on therapeutic exercise, separate from other timed codes.
6. Separate 97110 clearly from the adjustment, documenting distinct time, technique, and purpose.

Why Do CPT 97110 Claims Get Denied?

Most 97110 denials in chiropractic are preventable and trace back to a short list of patterns:

• Bundling into the adjustment: 97110 billed same-day as a CMT code without modifier 59 or the correct X subset gets absorbed by NCCI edits. Fix it by adding the modifier and documenting a distinct service.
• Missing GP modifier: Therapy codes without GP can reject at payers that route them through therapy edits. Fix it by appending GP whenever 97110 runs under a therapy plan of care.
• Billing Medicare as if covered: Submitting 97110 to Medicare without GY, or expecting payment, produces denials and audit exposure. Fix it by appending GY and billing the secondary or patient.
• Thin or cloned documentation: Repeated 97110 lines with no measurable outcome invite probe reviews. Fix it by documenting skilled care and functional progress every visit.
• Time not supported: Units that do not match documented one-on-one minutes fail the 8-minute rule. Fix it by logging exact minutes per timed code.
• Weak diagnosis link: A therapeutic exercise line unsupported by a functional diagnosis draws medical-necessity denials. Fix it by linking specific codes such as M62.81 (muscle weakness) alongside the subluxation code M99.03 (lumbar region).

How Much Does CPT 97110 Reimburse in 2026?

For providers Medicare does cover, the 2026 national non-facility payment for one unit of 97110 is roughly $30, calculated from the new non-qualifying-APM conversion factor of $33.40 in the CMS CY2026 Physician Fee Schedule final rule (CMS-1832-F). For chiropractors, that figure is academic: Medicare pays nothing for 97110, so your real rate is whatever your commercial and cash payers set.

2026 brought a first in Medicare history: two conversion factors, $33.57 for practices in a qualifying Advanced Payment Model and $33.40 for everyone else, up from a single $32.35 factor in 2025. That nudged the covered 97110 rate up slightly from about $28.79 per unit in 2025. None of that reaches a chiropractic claim, which is exactly why the commercial mix matters so much. For more on the conversion factor changes and how they interact with 2027 chiropractic Medicare payment changes, including the proposed same-day E/M cuts, see our 2027 same-day E/M billing guide.

Consider a real-world example. A chiropractic practice sees a commercial-insured patient three times a week for four weeks. Each visit includes a spinal adjustment plus two units of therapeutic exercise under 97110. If the commercial plan reimburses 97110 at $28 per unit, that is $56 per visit in therapeutic exercise, or about $672 across the 12 visits, on top of the manipulation revenue. Miss the modifier on those 97110 lines and NCCI bundling can erase the entire $672. That is the difference between a code that quietly funds your practice and one that quietly leaks revenue.

Frequently Asked Questions