First Edition By Dustin Passigli, PT, DPT, MA, CES, PES — Updated for 2026 by CoreMedical Group
Disclaimer: This article is for educational purposes only and should not be used as legal, billing, or compliance advice. Providers should verify payer-specific requirements and current CMS guidance before billing.
Why the 8 Minute Rule Matters More Than Ever in 2026
As Medicare enrollment continues to rise, physical therapists face increasing scrutiny around documentation, coding accuracy, and compliance. The Centers for Medicare & Medicaid Service’s (CMS) Therapy Services guidance reflects ongoing updates to outpatient therapy billing, including medical necessity, therapy thresholds, remote therapeutic monitoring, telehealth, and time-based coding requirements for 2026.
CMS also updated therapy thresholds, telehealth allowances, and Remote Therapeutic Monitoring (RTM) codes, all of which directly affect how PTs bill for services today.
What Is the 8 Minute Rule? (2026 Update)
The 8 Minute Rule is the CMS methodology used to determine how many units of timed therapeutic services can be billed under Medicare Part B. It applies to any service requiring direct, one-on-one patient contact.
CMS did not make any changes to the 8 Minute Rule or its unit thresholds for 2026; the methodology remains the same and is still defined in the Medicare Claims Processing Manual, Chapter 5.
2026 CMS Unit Thresholds
Misunderstanding the rule can lead to under-billing, delayed reimbursement, or audit exposure.
Who Must Follow the 8 Minute Rule?
This requirement has not changed for 2026; the same provider types listed in the first edition article are still required to follow the 8 Minute Rule under Medicare Part B.
The rule applies to all providers billing Medicare Part B, including:
- PTs, OTs, SLPs
- PTAs and OTAs
- Hospital outpatient departments
- SNFs billing Part B
- Home health agencies billing Part B
These provider requirements are defined by CMS in the Medicare Benefit Policy Manual, Chapter 15, which outlines all settings and clinicians who must follow Medicare Part B therapy billing rules, including the 8 Minute Rule. Every federal payer requires billing by the 8 minute rule. There are some cases where an insurance company will accept billing via SPM, or Substantial Portion Methodology, but the 8 minute rule is the standard in physical therapy billing for timed services. Commercial payers may follow different rules, such as the AMA midpoint rule, which is based on CPT® coding guidance published by the American Medical Association.
Timed vs. Untimed CPT Codes (2026)
Timed and untimed CPT code definitions are established by the American Medical Association’s CPT® coding guidance, which outlines evaluation codes, reevaluation codes, and supervised modalities such as hot/cold packs and unattended electrical stimulation.
Untimed Codes (Billed Once Per Session)
- PT evaluation (97161–97163)
- PT reevaluation (97164)
- Hot/cold packs (97010)
- Electrical stimulation, unattended (97014, G0283)
Timed CPT codes are defined by the American Medical Association’s CPT® coding guidance, which establishes these procedures as time-based services billed in 15 minute increments.
2026 CMS Updates Affecting Therapy Billing
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Updated KX Modifier Thresholds The 2026 KX modifier threshold for combined PT/SLP services is $2,480, as published in CMS’s Therapy Services guidance.
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New and Revised RTM Codes CMS added new RTM codes (98979, 98984, 98985) and revised descriptors for 98976 and 98977 in the 2026 Therapy Code List Annual Update.
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Telehealth Extended Through 2027 PTs, OTs, and SLPs may continue furnishing telehealth services through December 31, 2027, per CMS’s Telehealth FAQ.
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MPPR (Multiple Procedure Payment Reduction) The MPPR remains unchanged for 2026, with CMS continuing to apply a 50% reduction to the practice-expense component of subsequent therapy services billed on the same day, as outlined in the Medicare Claims Processing Manual, Chapter 5.
Billing Scenarios (2026 Examples)
These billing scenarios follow CMS’s total time methodology for timed therapeutic services as defined in the Medicare Claims Processing Manual, Chapter 5:
Scenario 1: Total Time Advantage
- 35 minutes therapeutic exercise
- 33 minutes therapeutic activity
Total = 68 minutes → 5 units
Scenario 2: Mixed Remainders
- 21 minutes neuromuscular reeducation
- 17 minutes therapeutic activity
Total = 38 minutes → 3 units
The Rule of Eights vs. the 8 Minute Rule
Some commercial payers use the Rule of Eights, which calculates units per CPT code rather than by total treatment time. This methodology is based on AMA CPT® coding guidance, not Medicare policy.
AMA’s Midpoint Rule (Used by Some Non-Federal Payers)
Some private insurers use AMA’s midpoint thresholds, which allow billing a unit once more than half of the typical time for a service is met. This methodology is based on AMA CPT® guidance. Medicare does not use this methodology.
- 1 unit at 7 min 31 sec
- 2 units at 22 min 31 sec
- 3 units at 37 min 31 sec
Conclusion
For any physical therapist billing federal payers, understanding the 8 Minute Rule is essential for compliance, reimbursement accuracy, and audit protections. With continued CMS focus on documentation, coding accuracy, and compliance, along with expanding Telehealth and RTM billing options, PTs must stay current on coding rules, thresholds, and payer-specific requirements.
CoreMedical Group continues to support PTs navigating these changes and advancing patient care.
