Insurance Appeals

CPT 97110 Physical Therapy Appeal Template: Complete PT Denial Guide 2025

Get free CPT 97110 appeal templates for therapeutic exercise denials. Includes 8-minute rule documentation, medical necessity examples, and insurance-specific guidance. 86% success rate.

AJ Friesl - Founder of Muni Health
October 25, 2025
12 min read
Quick Answer:

To appeal a CPT 97110 (therapeutic exercise) denial, submit a written appeal within 180 days including: (1) original denial letter and claim, (2) medical necessity justification showing functional limitations and goals, (3) time-based documentation meeting the 8-minute rule (8+ minutes = 1 unit), (4) treatment notes showing skilled intervention and patient progress, (5) supporting clinical guidelines and evidence-based research. Standard appeals receive decisions within 30-60 days.

Understanding CPT 97110 Denials: Why Physical Therapy Claims Get Rejected

CPT 97110 (therapeutic exercise to develop strength, endurance, range of motion, and flexibility) is one of the most frequently denied physical therapy codes. Independent physical therapy practices face denial rates of 18-24% on CPT 97110 claims—and most denials are completely legitimate services that simply lack proper documentation.

Here's the financial reality: if your practice bills 50 units of CPT 97110 per week at $30 per unit, an 18% denial rate costs you $14,040 annually in lost revenue. Most practices don't appeal every denial because manual appeals take 45-60 minutes per claim. That time constraint means you're leaving thousands on the table.

The good news? According to Kaiser Family Foundation data, up to 50% of denied claims can be successfully appealed—but less than 1% of doctors ever challenge these denials. For physical therapy specifically, properly documented CPT 97110 appeals succeed at rates between 67-72%.

Key Statistics

  • 22% average CPT 97110 denial rate across major insurers
  • 67-72% appeal success rate for properly documented appeals
  • $14,000+ annual revenue loss for typical PT practice due to denials
  • 45-60 minutes per appeal using manual methods

Common CPT 97110 Denial Reasons

Insurance companies deny CPT 97110 claims for specific, predictable reasons:

1. Time Documentation Issues (8-Minute Rule Violations) The 8-minute rule requires at least 8 minutes of therapeutic exercise to bill one unit. Incomplete or missing time documentation is the #1 denial reason. Common errors include billing 2 units for 20 minutes (should be 1 unit) or lacking precise start/stop times.

2. Medical Necessity Not Established Insurers deny claims when documentation doesn't show why therapeutic exercise requires skilled physical therapy intervention rather than a home exercise program. You must demonstrate functional limitations that necessitate professional supervision.

3. Insufficient Progress Documentation For subsequent visits, insurers require evidence of meaningful functional improvement. Generic statements like "patient tolerated treatment well" won't cut it. You need objective measurements: ROM degrees, strength grades, functional test scores.

4. Missing Physician Certification Medicare and many commercial insurers require a certified physician plan of care. Claims without valid physician certification or recertification get automatically denied (denial code: CO-16).

5. Bundling and Modifier Errors CPT 97110 bundles with certain codes per NCCI edits. Billing 97110 with 97112 in the same 15-minute interval without proper documentation supporting distinct services triggers denial code CO-97.

6. Mismatched CPT-ICD Codes ICD-10 diagnosis codes must support the medical necessity of therapeutic exercise. A diagnosis of "knee pain" (M25.561) without documented functional limitations won't justify multiple weeks of 97110.

7. Services Exceed Coverage Limits Some plans limit therapy visits per year (e.g., 20 visits) or require prior authorization after 6 visits. Exceeding these thresholds without authorization results in denial code CO-50.

Medical Necessity Requirements for CPT 97110 Appeals

To overturn a CPT 97110 denial, your appeal must prove medical necessity and skilled care requirement. Here's what insurance companies require:

The Four Pillars of Medical Necessity Documentation

1. Functional Deficit Identification Document specific functional limitations that impact activities of daily living (ADLs) or instrumental activities of daily living (IADLs):

  • ROM limitations: "Limited shoulder flexion to 95° (uninvolved side: 170°) prevents patient from reaching overhead cabinets or washing hair independently."
  • Strength deficits: "Right quadriceps strength 3/5 vs 5/5 left. Patient requires assistive device for stair climbing and reports difficulty standing from chair."
  • Endurance impairments: "Patient tolerates 3 minutes of ambulation before requiring rest due to hip extensor weakness, limiting community mobility."

Notice the pattern: clinical measurement → functional impact. Never document ROM/strength in isolation.

2. Skilled Intervention Justification Explain why therapeutic exercise requires a physical therapist's expertise rather than independent exercise:

  • Complex exercise sequencing requiring therapist assessment
  • Manual resistance/assistance during exercises
  • Continuous monitoring for compensatory movement patterns
  • Progressive exercise modification based on patient response
  • Education on proper technique to prevent injury

Once the patient can safely perform exercises independently without frequent progression, the service becomes non-skilled and non-covered.

3. Evidence-Based Treatment Rationale Reference clinical practice guidelines supporting therapeutic exercise for the patient's diagnosis:

  • APTA Clinical Practice Guidelines (by condition)
  • Published research on therapeutic exercise efficacy
  • Medical specialty society position statements
  • CMS coverage determinations (LCDs) for therapy services

Example: "APTA guidelines for knee osteoarthritis recommend progressive strengthening exercises to improve joint stability and reduce pain, supported by Level I evidence (Hochberg et al., Arthritis Care & Research)."

4. Measurable Functional Progress Show objective improvement toward functional goals:

| Outcome Measure | Initial | Current | Goal | |----------------|---------|---------|------| | Shoulder Flexion ROM | 95° | 135° | 160° | | QuickDASH Score | 52 | 38 | <20 | | Timed Up & Go Test | 18 sec | 13 sec | <10 sec |

Functional progress demonstrates the treatment is clinically meaningful and responsive to therapy.

CPT 97110 Appeal Letter Template

Use this template as your foundation, customizing the clinical details to match your specific case:

[Your Practice Letterhead]

[Date]

[Insurance Company Name]
Appeals Department
[Address from denial letter]

RE: Appeal of Claim Denial
Patient: [Full Name]
Policy/Member ID: [Number]
Claim Number: [Number]
Date(s) of Service: [Date range]
CPT Code: 97110 (Therapeutic Exercise)
Denial Code: [CO-50, CO-97, etc.]
Denial Reason: [As stated on EOB]

Dear Appeals Reviewer:

I am writing to appeal the denial of CPT code 97110 (therapeutic exercise) for the above-referenced patient. This service was medically necessary, properly documented, and meets all coverage criteria. I respectfully request reconsideration based on the following clinical justification.

CLINICAL PRESENTATION & FUNCTIONAL LIMITATIONS

[Patient name] presented on [date] with [primary diagnosis - ICD-10 code] resulting from [mechanism of injury/condition onset]. Objective examination revealed:

- [Specific ROM limitation with degrees and functional impact]
- [Strength deficit with manual muscle test grades and functional impact]
- [Endurance/pain limitation with objective measure and functional impact]

These impairments directly limited the patient's ability to [list 3-4 specific ADL/IADL limitations: dressing, grooming, work duties, household tasks, etc.].

MEDICAL NECESSITY JUSTIFICATION

Therapeutic exercise (CPT 97110) was medically necessary to address these functional deficits. The exercises performed required skilled physical therapy intervention for the following reasons:

1. [Reason 1: e.g., "Complex exercise sequencing requiring progressive adjustment based on patient tolerance"]
2. [Reason 2: e.g., "Manual resistance application and real-time correction of compensatory movement patterns"]
3. [Reason 3: e.g., "Frequent exercise modification to prevent injury risk due to joint instability"]

The treatment approach is consistent with American Physical Therapy Association Clinical Practice Guidelines for [condition], which recommend progressive strengthening and ROM exercises as first-line intervention (Level I evidence).

DOCUMENTATION OF SERVICES PROVIDED

Each session of CPT 97110 included direct, one-on-one therapeutic exercise with skilled PT supervision:

Date of Service: [Date]
Total Treatment Time: [X] minutes
CPT 97110 Time: [X] minutes ([X] units per 8-minute rule)

Exercises performed:
- [Exercise 1]: [Sets/reps, resistance, purpose]
- [Exercise 2]: [Sets/reps, resistance, purpose]
- [Exercise 3]: [Sets/reps, resistance, purpose]

[Include table of all denied dates with time documentation]

FUNCTIONAL OUTCOMES ACHIEVED

The patient demonstrated measurable functional improvement as a direct result of therapeutic exercise:

[Include outcome measure table showing baseline → current → goal]

These improvements enabled the patient to [list functional gains: return to work, independent ADLs, etc.].

RESPONSE TO SPECIFIC DENIAL REASON

[If denied for time documentation]: The treatment record clearly documents [X] minutes of therapeutic exercise, exceeding the 8-minute threshold required for [X] unit(s) of CPT 97110.

[If denied for medical necessity]: The clinical documentation establishes both functional deficit and skilled intervention requirement, meeting CMS criteria for covered therapy services per Chapter 15 of the Medicare Benefit Policy Manual.

[If denied for bundling (CO-97)]: CPT 97110 was performed during a distinctly separate 15-minute interval from [other code], as documented in the treatment timeline. These were not overlapping services.

SUPPORTING DOCUMENTATION ENCLOSED

- Complete evaluation with functional outcome measures
- Treatment notes for all denied dates of service
- Physician plan of care with certification signature
- Published clinical guidelines supporting treatment approach
- Progress notes showing functional improvement
- [Any additional relevant documents]

CONCLUSION & REQUESTED ACTION

The therapeutic exercise provided to [patient name] was medically necessary, properly documented, and resulted in meaningful functional improvement. The services meet all coverage criteria established by [insurance company name] and CMS guidelines.

I respectfully request that you overturn this denial and process payment for CPT 97110 for the dates of service listed above, totaling $[amount].

Please do not hesitate to contact me at [phone] or [email] if you require additional information to complete your review.

Sincerely,

[Your Name], PT, DPT
[License Number]
[Practice Name]
[Phone]
[Email]

Enclosures: [List all attached documents]

Appeal Deadline Critical

Most insurance companies require appeals within 180 days of the denial date (Medicare: 120 days). Missing this deadline means forfeiting your right to appeal, regardless of medical necessity. Check your denial letter for the specific deadline.

The 8-Minute Rule: Documentation Requirements for Time-Based Appeals

The 8-minute rule determines how many units of CPT 97110 you can bill based on total treatment time. Incorrect time documentation is the most common—and most preventable—denial reason.

8-Minute Rule Calculation Chart

| Total Minutes | Billable Units | |--------------|----------------| | 8-22 minutes | 1 unit | | 23-37 minutes | 2 units | | 38-52 minutes | 3 units | | 53-67 minutes | 4 units | | 68-82 minutes | 5 units |

The Formula: Total timed code minutes ÷ 15, then round to nearest whole number.

Example 1: 20 minutes of therapeutic exercise = 1 unit (20÷15 = 1.33, rounds to 1) Example 2: 28 minutes of therapeutic exercise = 2 units (28÷15 = 1.87, rounds to 2)

What Your Time Documentation Must Include

Insurance auditors look for these specific elements:

Start and stop times (not just total minutes) ✅ Specific exercises performed (not "therapeutic exercise per POC") ✅ Exercise parameters: sets, reps, resistance, assistance level ✅ Patient response to exercises during the session ✅ Skilled intervention provided during exercise performance ✅ Clear separation from other timed codes (97112, 97140, etc.)

Common 8-Minute Rule Documentation Errors

Error 1: Billing 2 units for 20 minutes Correct billing: 1 unit (20 minutes falls in 8-22 minute range)

Error 2: Vague time documentation Wrong: "Pt participated in therapeutic exercise for approximately 30 minutes." Right: "Therapeutic exercise 9:15-9:43am (28 minutes): Seated leg press 3×12 @40lbs..."

Error 3: Including rest time Rest breaks between exercises don't count toward CPT 97110 time. Document only active exercise time.

Error 4: Overlapping time with other codes If you bill 97110 (9:00-9:15) and 97112 (9:10-9:25), you have overlapping time. Must document distinct 15-minute intervals or use Modifier 59.

Sample Time-Based Documentation

Here's acceptable documentation for 3 units of CPT 97110:

Therapeutic Exercise (CPT 97110): 9:15-9:58am (43 minutes, 3 units)

  1. Seated leg press (bilateral): 3 sets × 12 reps @ 40lbs. PT provided verbal cueing for proper knee alignment and manual resistance during eccentric phase. Patient tolerated without increased pain.

  2. Standing hip abduction (R): 3 sets × 10 reps with 2lb ankle weight. PT provided tactile cueing at gluteus medius to prevent trunk lean. Improved control noted compared to previous session.

  3. Prone hamstring curls: 2 sets × 15 reps @ 15lbs. PT monitored for lumbar compensation. Patient able to complete without substitution patterns.

  4. Standing march with resistance band: 3 sets × 20 reps. PT progressed resistance from yellow to red band based on patient performance. Improved endurance (no rest required between sets vs previous session).

Patient response: Tolerated exercise progression well. Reports decreased knee pain with stairs (5/10 → 3/10). Functional improvement noted in stair-climbing mechanics.

Notice: Specific exercises, parameters (sets/reps/resistance), skilled intervention during exercise, and patient response.

Insurance Company-Specific CPT 97110 Appeal Requirements

Each major insurer has specific policies for CPT 97110 coverage and appeals. Here's what you need to know:

Aetna CPT 97110 Appeal Process

Coverage Policy: Aetna Clinical Policy Bulletin (CPB) 0325 - Physical Therapy

  • Covers therapeutic exercise when medically necessary to restore function
  • Requires documented functional deficits impacting ADLs
  • Supports telehealth delivery with appropriate modifiers (GT or 95)

Appeal Requirements:

  • Timeline: 180 days from denial date
  • Submission: Fax to provider services or online portal
  • Documentation: Include standardized outcome measures (FOTO, LEFS, QuickDASH)
  • Success rate: 67% for properly documented appeals

Aetna-Specific Tips:

  • Reference CPB 0325 in your appeal letter
  • Cite specific functional limitations impacting work/ADLs
  • Include comparative outcome measures (baseline vs current)
  • For telehealth denials, confirm use of synchronous audiovisual platform

UnitedHealthcare CPT 97110 Appeals

Prior Authorization Requirements (as of January 2025):

  • Initial evaluation: No PA required
  • First 6 visits: No PA required if within 8 weeks of initial evaluation
  • After 6 visits: Prior authorization required

Coverage Criteria:

  • Medical necessity based on CMS Chapter 15 criteria
  • Services must show skilled care requirement
  • InterQual criteria used for PA decisions

Appeal Process:

  • Timeline: 180 days (commercial), 65 days (Medicare Advantage)
  • Submission: UHC Provider Portal preferred
  • Documentation: Treatment plan must show specific functional goals with timelines
  • Gold Card Program: If you have Gold Card status, appeals may be expedited

Common UHC Denial Codes:

  • CO-50: Medical necessity not met → include functional outcomes data
  • CO-97: Bundled services → add Modifier 59 if distinct
  • CO-16: Missing physician certification → submit signed plan of care

Blue Cross Blue Shield CPT 97110 Appeals

Coverage Policies: (Vary by state - verify your specific BCBS plan)

  • Generally follows Medicare guidelines for therapy services
  • Requires medical necessity demonstration
  • May have annual visit limits (commonly 20-30 visits)

Appeal Timeline:

  • 180 days from denial date
  • 60-day decision timeline from appeal receipt

BCBS-Specific Documentation:

  • Include treating physician's prescription/referral
  • Reference state-specific BCBS medical policy (e.g., "per BCBS Texas Medical Policy 2.04.109")
  • Show objective outcome measures (goniometry, MMT grades, validated functional scales)
  • Document failed conservative treatment attempts when appropriate

Submission Method:

  • Electronic via Availity Essentials (preferred - allows documentation upload)
  • Fax to provider services (number on denial letter)
  • Mail to address on EOB (slowest option)

Medicare CPT 97110 Appeals

Coverage Criteria:

  • Medicare Benefit Policy Manual Chapter 15: Covered when services require skilled care
  • No unit limit per session, but must justify medical necessity
  • Typically allows 6 units per session; more requires exceptional documentation
  • 2 visits per week usually covered without question; more requires strong justification

Medicare Appeal Levels:

Level 1 - Redetermination (120-day deadline):

  • Submit to Medicare Administrative Contractor (MAC)
  • Include: Denial notice, medical records, physician justification
  • Decision timeline: 60 days

Level 2 - Reconsideration (180 days from Level 1 decision):

  • Qualified Independent Contractor (QIC) review
  • Can submit additional evidence
  • Decision timeline: 60 days

Medicare-Specific Documentation:

  • Physician certification required every 90 days
  • Treatment plans must show expected goals and timeframes
  • Progress notes must demonstrate "clinically meaningful" improvement
  • When progress plateaus, document why continued skilled care needed

Success Tip: Medicare heavily scrutinizes "maintenance therapy." If patient has reached plateau but still needs skilled care, document specific risks of regression and complexity requiring PT expertise (e.g., "Patient requires skilled PT monitoring for safe exercise progression due to cardiac comorbidity and fall risk").

Cigna Physical Therapy Appeals

Coverage Policy:

  • Follows evidence-based guidelines for therapy services
  • Utilizes CoverMyMeds platform for some authorization workflows

Appeal Requirements:

  • Timeline: 180 days
  • Submission: Cigna provider portal or fax
  • Documentation: Must include treatment plan with measurable goals

Denial Code Translation:

  • CO-50: Add functional outcome measures
  • Ensure diagnosis codes support therapy need

How Muni Appeals Automates CPT 97110 Appeals

If you're spending 45-60 minutes per CPT 97110 appeal, you're losing money even when you win. A $90 claim that takes an hour to appeal costs you more in staff time than the reimbursement. That's why 99% of denied CPT 97110 claims never get appealed—it's not economically viable.

Muni Appeals solves this problem by automating the entire appeal process for physical therapy denials.

How It Works for CPT 97110 Denials

1. Upload Your Denial (30 seconds) Take a photo of the EOB showing the CPT 97110 denial or upload the electronic denial. Muni extracts the denial code, date of service, and patient information automatically.

2. AI Compiles Your Documentation (4 minutes) Muni's AI pulls together everything needed for your appeal:

  • Treatment notes from your EMR showing exercise specifics and time
  • 8-minute rule calculation and compliance verification
  • Functional outcome measures demonstrating progress
  • Relevant APTA clinical practice guidelines
  • Insurance company-specific policy citations (Aetna CPB numbers, UHC PA criteria, etc.)
  • Proper appeal letter formatting per insurer requirements

3. Physical Therapist Review (1 minute) Review the compiled appeal for clinical accuracy. Make any necessary edits to the clinical reasoning or add context.

4. Submit Directly to Insurance Company (automated) Muni sends the appeal to the correct insurance company address (fax, portal, or mail) and tracks the 30-60 day decision timeline.

Why Muni Wins More CPT 97110 Appeals

Insurance-Specific Knowledge: Every insurance company has different coverage policies for CPT 97110. Muni automatically applies the right criteria:

  • Aetna CPB 0325 language
  • UHC Gold Card Program references
  • Medicare Chapter 15 medical necessity standards
  • BCBS state-specific policies

8-Minute Rule Compliance: Muni calculates billable units based on your documented time and flags any discrepancies before submission. No more CO-50 denials due to time rule errors.

Outcome Measures Integration: Muni pulls standardized outcome measures from your documentation (FOTO scores, QuickDASH, LEFS) and presents them in comparison tables that auditors expect to see.

Clinical Guideline Citations: Every appeal includes relevant evidence-based guidelines supporting therapeutic exercise for the patient's specific diagnosis—automatically researched and cited in proper format.

The ROI for Physical Therapy Practices

Manual Appeal:

  • Time: 45-60 minutes per appeal
  • Cost: $30-45 in staff time (at $40/hour)
  • Success rate: 67% (industry average)
  • Economic threshold: Not worth appealing claims under $100

With Muni Appeals:

  • Time: 5 minutes per appeal
  • Cost: $3-4 in staff time
  • Success rate: 86% (Muni user data)
  • Economic threshold: Worth appealing any claim over $20

Annual Impact for Typical PT Practice:

  • CPT 97110 claims per year: 2,500
  • Denial rate: 22% = 550 denied claims
  • Average denial amount: $90
  • Total denied revenue: $49,500

Without appeals: Recover $0 (appeals not economically viable) With Muni Appeals: Recover $38,115 (550 appeals × 86% success × $90 × 97% net of Muni cost)

Net revenue recovery: $37,000+ annually

Start 3 Free Appeals →

Frequently Asked Questions About CPT 97110 Appeals

What is CPT code 97110 used for in physical therapy?

CPT 97110 is used for therapeutic exercise procedures to develop strength, endurance, range of motion, and flexibility. It's a time-based code billed in 15-minute increments and requires direct one-on-one patient contact with skilled physical therapy intervention. Common exercises include strengthening programs, stretching exercises, ROM activities, and endurance training.

How do you document medical necessity for CPT 97110?

Medical necessity for CPT 97110 requires four elements: (1) specific functional deficits documented with objective measurements (ROM degrees, strength grades, functional test scores), (2) explanation of how deficits impact ADLs or IADLs, (3) justification why exercises require skilled PT intervention rather than home program, (4) evidence of meaningful functional progress toward documented goals. Reference clinical practice guidelines supporting therapeutic exercise for the patient's diagnosis.

What is the 8-minute rule for CPT 97110?

The 8-minute rule determines billable units: 8-22 minutes = 1 unit, 23-37 minutes = 2 units, 38-52 minutes = 3 units. Calculate by dividing total timed code minutes by 15 and rounding to the nearest whole number. Documentation must include specific start/stop times, exercises performed with parameters (sets/reps/resistance), and skilled intervention provided. Rest breaks don't count toward billable time.

Why do insurance companies deny CPT 97110 claims?

The most common denial reasons are: (1) insufficient time documentation or 8-minute rule violations (denial code CO-50), (2) medical necessity not established in documentation, (3) missing or inadequate progress documentation for subsequent visits, (4) lack of physician certification for Medicare plans (CO-16), (5) bundling with other codes without proper modifiers (CO-97), (6) mismatched ICD-10 codes that don't support therapy need, (7) exceeding coverage limits without prior authorization.

How long does a physical therapy appeal take?

Standard appeals receive decisions within 30-60 days from submission. Medicare Level 1 redeterminations: 60 days. Expedited appeals (when delay could harm patient health): 72 hours. Most commercial insurers follow similar timelines. You must submit your appeal within 180 days of the denial date (120 days for Medicare) or you forfeit appeal rights. Track your deadline carefully and follow up if no decision received within the expected timeline.

Can I appeal a bundled CPT 97110 claim denial?

Yes. Bundling denials (CO-97) occur when CPT 97110 is billed with another code that the insurer considers part of the same service. To appeal: (1) review NCCI edit pairs to verify if codes can be billed together, (2) document that services were performed during distinctly separate 15-minute intervals, (3) resubmit claim with Modifier 59 appended to the secondary code to indicate distinct service, (4) include treatment timeline showing separation. Success rate: 89% when services are truly distinct with proper documentation.

What documentation is required for CPT 97110 appeals?

Required documentation includes: (1) original denial letter and EOB, (2) complete evaluation with functional outcome measures, (3) treatment notes for all denied dates showing time, exercises, parameters, skilled intervention, and patient response, (4) physician plan of care with certification signature, (5) progress notes demonstrating measurable functional improvement, (6) relevant clinical practice guidelines supporting treatment, (7) insurance company-specific forms if required. Organize chronologically with claim information clearly identified.

Should I appeal a denied CPT 97110 claim under $50?

Traditionally no—manual appeals cost $30-45 in staff time, making small claim appeals unprofitable. However, with automated tools like Muni Appeals (5-minute appeal preparation), the economics change. At $3-4 in staff time, any claim over $20 becomes worth appealing. Consider batch appealing multiple small denials together to maximize efficiency. Also consider the precedent: if the insurer learns you don't appeal certain denial types, they may deny more aggressively.

Can Muni Appeals automate CPT 97110 physical therapy appeals?

Yes. Muni Appeals specializes in automating PT denial appeals. Upload your CPT 97110 denial, and Muni's AI compiles the appeal in 5 minutes including: 8-minute rule calculation verification, medical necessity justification with functional outcomes, insurance-specific policy citations (Aetna CPB 0325, UHC criteria, Medicare Chapter 15), relevant APTA clinical practice guidelines, and proper appeal letter formatting. Success rate: 86% vs 67% industry average. Worth appealing claims as small as $20 due to minimal time investment.

Common Mistakes That Torpedo CPT 97110 Appeals

Even strong clinical cases fail when appeals contain these errors:

Generic Exercise Descriptions Wrong: "Patient performed therapeutic exercises per POC." Right: "Standing hip abduction 3×10 with 2lb ankle weight, manual resistance during eccentric phase to target gluteus medius weakness (3/5 MMT) limiting single-leg stance."

Missing Functional Link Wrong: "Patient's shoulder flexion increased from 95° to 135°." Right: "Shoulder flexion increased from 95° to 135°, enabling patient to return to overhead reaching tasks required for work as electrician."

Time Documentation Errors Wrong: "Approximately 30 minutes of exercise." Right: "Therapeutic exercise 9:15-9:43am (28 minutes, 2 units per 8-minute rule)."

Failing to Address Specific Denial Reason Don't write a generic appeal. Directly respond to the stated denial reason (medical necessity, time documentation, bundling, etc.) with specific evidence countering the denial.

No Objective Outcome Measures Subjective statements like "patient improving" don't convince insurers. Use validated outcome measures: QuickDASH scores, goniometric ROM measurements, timed functional tests (TUG, 6-minute walk), strength grades.

Missing Deadline Check the appeal deadline on your denial letter (usually 180 days, Medicare 120 days). Late appeals get automatically rejected regardless of merit.

Ready to Stop Losing Revenue to CPT 97110 Denials?

Physical therapy practices leave an average of $14,000+ on the table annually because appealing CPT 97110 denials manually isn't economically viable. When a single appeal takes 45-60 minutes, you can't afford to fight for a $60 claim—even though you'd win 67% of the time.

Muni Appeals changes the economics. At 5 minutes per appeal and an 86% success rate, every CPT 97110 denial becomes worth fighting for.

With Muni Appeals, you can:

  • ⚡ Generate complete appeals in 5 minutes (vs 45-60 minutes manual)
  • 📈 Achieve 86% success rate (vs 67% industry average)
  • 💰 Recover $14,000-37,000+ annually in denied PT claims
  • 🎯 Automatic 8-minute rule compliance checking
  • 📋 Insurance-specific policy citations (Aetna CPB, UHC criteria, Medicare Chapter 15)
  • 🔗 APTA clinical guideline integration
  • ⏱️ Appeal deadline tracking and automated reminders

Independent physical therapy practices using Muni Appeals recover an average of $23,000 annually in CPT 97110 denials alone—revenue that was previously left unclaimed because manual appeals weren't economically feasible.

Start 3 Free Appeals and see how much denied revenue you're leaving on the table.


This guide reflects 2025 CPT 97110 appeal procedures and 8-minute rule requirements. Insurance company policies and state regulations may vary. Muni Appeals maintains current appeal procedures for all major insurance companies including Aetna, UnitedHealthcare, Blue Cross Blue Shield, Cigna, Humana, and Medicare.

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