What Is the 8-Minute Rule?
Under Medicare policy for timed outpatient therapy services, billable units are determined by total skilled, one-on-one treatment time. Each unit represents a 15-minute increment, and Medicare allows a unit to be billed when the time for that unit is at least 8 minutes (“more than half” of the 15-minute midpoint).[1][2]
Professional associations (APTA, ASHA) describe the 8-Minute Rule as Medicare’s method and note that some commercial payers may instead apply CPT’s “midpoint” interpretation or other payer-specific policies. Providers should verify the applicable rule with each payer.[3][4]
How to Apply the Rule (Minutes → Units)
The following Medicare time ranges are widely cited in CMS guidance for timed services (15-minute units):[2][5]
| Billable Units | Total Timed Minutes (Same Date of Service) |
|---|---|
| 1 unit | 8–22 minutes |
| 2 units | 23–37 minutes |
| 3 units | 38–52 minutes |
| 4 units | 53–67 minutes |
| 5 units | 68–82 minutes |
| 6 units | 83–97 minutes |
In practice, Medicare sums the minutes of all timed codes for the day, divides by 15 to determine whole units, and then applies the “≥8 minutes remainder” threshold to determine if one additional unit can be billed.[2][6]
Worked Example
Suppose a therapist documents 41 total minutes of skilled, one-on-one treatment (all timed codes) on a single date of service. 41 ÷ 15 = 2 full 15-minute units with 11 minutes remaining. Because the remainder is ≥ 8 minutes, Medicare allows billing 3 units for that date of service.[2][4]
If only 37 minutes were documented, 37 ÷ 15 = 2 full units with 7 minutes remaining; the remainder is < 8 minutes, so the claim would generally be for 2 units.[2]
Multiple Timed Codes on the Same Day
When multiple timed services are furnished on the same date, Medicare sums the minutes across those services to determine the total number of billable units. Allocation of units among the specific CPT codes should be supported by documentation of the minutes spent on each service and payer rules; follow CMS guidance and local carrier instructions as applicable.[2][6]
Important Limitations and Payer Variation
- Medicare vs. CPT midpoint: APTA notes a distinction between Medicare’s 8-Minute Rule and the CPT manual’s “passing the midpoint” standard that some non-Medicare payers may apply. Always check the specific payer policy.[3]
- Timed vs. Untimed codes: The 8-Minute Rule applies to timed codes (15-minute increments). Untimed codes (e.g., evals) are billed differently and aren’t governed by the 8-Minute Rule.[4]
- Documentation must support minutes: Units billed must be backed by defensible documentation of skilled, one-on-one treatment time that meets medical necessity and coverage criteria.[1]
References
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Centers for Medicare & Medicaid Services (CMS). Outpatient Rehabilitation Therapy Services (MLN Booklet MLN905365): “They must provide more than the 15-minutes midpoint (that is, 8 minutes or more — also known as the 8-minute rule).”
CMS MLN Booklet PDF -
CMS. Medicare Claims Processing Manual, Chapter 5 (Part B). Time-based billing intervals show 1 unit = 8–22 minutes; 2 units = 23–37; 3 units = 38–52; 4 units = 53–67; etc.
CMS Claims Processing Manual -
American Physical Therapy Association (APTA). Coding for Timed Codes — describes differences between Medicare’s 8-Minute Rule and CPT midpoint standard.
APTA Coding for Timed Codes -
American Speech-Language-Hearing Association (ASHA). Timed & Untimed Codes FAQs.
ASHA Timed Codes FAQs -
ASHA. Medicare CPT Coding Rules for Speech-Language Pathology Services.
ASHA SLP Coding Rules -
CMS. Therapy Services — CMS page describing therapy billing topics; includes references to the 8-minute provision in context of timed services and modifiers.
CMS Therapy Services