Occupational Therapy CPT Codes: 97165 to 97168, 97110, 97530, 97535

Codes verified against the CMS 2026 fee schedule files, the Medicare billing article A56566 and AOTA's CPT evaluation descriptors. Reviewed . See sources.

What are the main occupational therapy CPT codes?

OT evaluations are billed with 97165 (low complexity), 97166 (moderate), 97167 (high) and 97168 (re-evaluation), each as one untimed unit. Treatment is often billed with timed 15 minute codes: 97110 therapeutic exercise, 97530 therapeutic activities, and 97535 self-care and home management training. Medicare claims add the GO modifier.

Occupational therapy billing splits into two kinds of codes. Evaluations are untimed: the complexity of the evaluation, not the clock, picks the code. Most treatment codes are timed in 15 minute units, and Medicare counts units from the total timed minutes in the session.

This page explains each code, how units are counted, and what a treatment note should show. It draws on the CMS fee schedule files, AOTA's summary of the evaluation descriptors, and the Medicare billing article for outpatient PT and OT services linked below. For profession-specific documentation help, see WellNotes for occupational therapists.

Core occupational therapy CPT codes

Core occupational therapy CPT codes
CodeWhat it covers (paraphrased)Timed or untimed
97165OT evaluation, low complexity: brief history, 1 to 3 performance deficits, low complexity decision making. CPT lists 30 minutes as typical face-to-face time.Untimed, 1 unit
97166OT evaluation, moderate complexity: expanded history, 3 to 5 performance deficits, moderate decision making. Typically 45 minutes.Untimed, 1 unit
97167OT evaluation, high complexity: extensive history, 5 or more performance deficits, high decision making. Typically 60 minutes.Untimed, 1 unit
97168OT re-evaluation of an established plan of care, with a revised plan of care.Untimed, 1 unit
97110Therapeutic exercise to develop strength, endurance, range of motion and flexibility, one or more areas.Timed, each 15 minutes
97530Therapeutic activities: direct one-on-one use of dynamic activities to improve functional performance.Timed, each 15 minutes
97535One-on-one training in daily living tasks at home, such as dressing, cooking, staying safe and using adaptive equipment.Timed, each 15 minutes

How do you choose 97165, 97166 or 97167?

AOTA's summary of the CPT descriptors lists three required components for every OT evaluation: an occupational profile with medical and therapy history, an assessment of performance deficits, and clinical decision making. The level is set by the depth of the history (brief, expanded, extensive), the number of performance deficits identified (1 to 3, 3 to 5, 5 or more), and the complexity of decision making, including comorbidities and whether tasks had to be modified for the client to complete the evaluation. AOTA notes that each component in the descriptor must be documented to report the chosen level.

Re-evaluation (97168) is not routine. The Medicare billing article says indications include new clinical findings, a significant change in condition, or failure to respond to the interventions in the plan of care, and that re-evaluations are not billed just to update a plan of care, recertify, or write a progress report.

97110 vs 97530 vs 97535: which treatment code?

Pick the code by the purpose of the activity, not the equipment. The Medicare article says exercise taught and performed to restore strength, range of motion, endurance or flexibility is 97110. Therapeutic activities (97530) use dynamic functional activities to improve performance. Self-care and home management training (97535) covers ADL and compensatory training, safety procedures, and instruction in adaptive equipment for use at home.

The same article warns that 97535 should not be used for every home instruction. Teaching a home exercise program for strength is 97110; teaching the client to use a sock aid for dressing is 97535.

How does the 8-minute rule work for OT?

Medicare counts timed units from the total timed minutes for one discipline on one date. Noridian states that a timed code needs at least 8 minutes of direct treatment to be billed, and the Medicare billing article gives the chart below. Untimed evaluation minutes are not added to the timed total.

The article's example: 20 minutes of 97110 plus 20 minutes of 97535 gives 40 timed minutes, which supports 3 units. Units are then assigned to codes by their 15 minute blocks and remaining minutes. The article also tells therapists to record actual minutes as "Timed Code Treatment Minutes" and "Total Treatment Time", not time in and time out or units.

Medicare timed units by total timed minutes
Total timed minutesUnits
8 to 221
23 to 372
38 to 523
53 to 674
68 to 825
Under 8Not billed

Which modifiers go on OT claims?

  • GO: services delivered under an outpatient occupational therapy plan of care. Noridian says it goes in the first or second modifier position when other modifiers are needed.
  • CO: OT services furnished in whole or in part by an occupational therapy assistant. CMS pays these at 85 percent of the otherwise applicable fee schedule amount.
  • KX: added when a client's therapy goes over the annual Medicare KX threshold amount. CMS says claims over the threshold without KX are denied.
  • 95: CMS names modifier 95 for outpatient therapy by telehealth from OTs employed by hospitals. See the telehealth modifiers guide.

What should the session note show?

  • Objective measures of the deficit being treated (for example ADL performance, strength, range of motion) and how it affects function.
  • The specific activities or exercises performed, with the assistance level and instructions given, to show the skill of a therapist was required.
  • Timed Code Treatment Minutes and Total Treatment Time for the date, using actual minutes.
  • The client's response and progress toward plan of care goals.
  • For 97535, the ADL or safety task trained and the adaptive equipment used. Our OT documentation page and SOAP note template show the structure.

Common mistakes

  • Billing timed units from a rounded session length instead of the summed timed minutes.
  • Counting evaluation minutes toward timed treatment units.
  • Billing 97168 for a routine progress report or recertification.
  • Using 97535 for every home program, including exercise programs that belong under 97110.
  • Leaving off the GO modifier on Medicare outpatient OT claims.

Frequently Asked Questions

Is 97165 a timed code?

No. 97165, 97166, 97167 and 97168 are untimed and billed as one unit. CPT lists typical face-to-face times (30, 45 and 60 minutes for the three evaluation levels), but the level is chosen by the required components.

Can 97110 and 97530 be billed in the same session?

Yes, when each is a distinct, documented service and the total timed minutes support the units. Payers may apply NCCI edits, so check whether a modifier is needed.

How many units is 40 minutes of OT treatment?

Under the Medicare chart, 38 to 52 total timed minutes supports 3 units. The Medicare billing article uses 20 minutes of 97110 plus 20 minutes of 97535 as its example.

What does the GO modifier mean?

GO indicates services delivered under an outpatient occupational therapy plan of care. Noridian notes that claims from enrolled therapists without a therapy modifier (GN, GO or GP) are returned as unprocessable.

When is an OT re-evaluation billable?

When there are new clinical findings, a significant change in condition, or failure to respond to the plan of care. Medicare does not pay for routine re-evaluations done only to update a plan of care or write a progress report.

Related references

Sources

Payer rules vary. Confirm diagnosis, coverage, modifier, and documentation rules with each payer before billing. This page is general education, not billing, coding, or legal advice. The diagnosis is the treating clinician's decision.

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