At some point or another, almost every rehab therapist has commiserated with a colleague over the billing process. We know; it’s one of your least-favorite parts of the job. But, while it’s certainly less fulfilling than providing patient treatment, accurately reporting CPT codes is imperative to your ability to get paid. In other words, flubbing up on your billing duties can cost your clinic big bucks—and no one wants to leave cold-hard cash sitting on the table. And not to add insult to injury, but there are actually many different kinds of CPT codes in which you need to be familiar—including the rare-but-important pseudo-timed code. As with other CPT codes, billing pseudo-timed codes requires adherence to a strict set of rules. And accurately reporting them to CMS can ensure your wallet remains fat—during the holiday season and beyond.

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What’s the deal with untimed and direct-time codes?

First, let’s review the nuances of therapy-related procedural codes. Typically, the CPT codes used to bill for rehab therapy services fall into one of two categories: untimed or direct time. Service-based (or untimed) codes are used to denote one-off services, such as conducting an evaluation or reevaluation, or applying hot/cold packs. As the terminology suggests, it doesn’t matter if you complete untimed services in five minutes or an hour, because you can only bill for one code. Conversely, time-based (or direct time) codes—which apply to services like therapeutic exercise and manual therapy—fall under Medicare’s 8-Minute Rule. (It’s important to call out Medicare, specifically, as not all insurances follow Medicare’s version of this rule.) Essentially, you can bill one unit to Medicare for each 15-minute increment you spend providing time-based therapy services. That means you can bill two units for each 30-minute increment, three for each 45-minute increment, and so on. Furthermore, as the name of the 8-Minute Rule suggests, you must provide a service for at least eight minutes in order to bill a full unit; if you provide the service for seven or fewer minutes, you cannot bill for it.

How do pseudo-timed codes fit into the billing picture?

Okay, what about those pesky pseudo-timed codes? How do these codes fit into the billing spectrum? Glad you asked. Pseudo-timed codes (no, we’re not talking about phony codes) aren’t yet defined by CMS. But, that doesn’t mean they’re some unknown entity or inexact science; actually, they demand your respect and full attention when billing for certain services.

CMS has proposed to distinguish pseudo-timed codes as an entirely separate category of direct-time codes, per the following definition: “CPT codes that are defined by a specific timeframe other than the traditional 15-minute interval.” So, think of these codes as a custom solution to reporting services that don’t fit the traditional timed-code bill. Here are some examples of pseudo-timed CPT codes:

  • 96125 - Standardized cognitive performance testing, per hour (OT)
  • 96105 - Assessment of aphasia, per hour (SLP)
  • 97545 - Work hardening/conditioning, first hour (OT)
  • 97546 - Work hardening/conditioning, each additional hour (OT)
  • 92607 - Evaluation for a prescription-alternative communication device, first hour (SLP)
  • 92608 - Evaluation for a prescription-alternative communication device, each additional 30 minutes (SLP)
  • 92626 - Evaluation of a patient’s auditory rehabilitation status, first hour (SLP)

Do pseudo-timed codes follow the same rules as direct-time codes?

As mentioned above, pseudo-timed codes are time-dependent, meaning they should be billed in units. However, the 8-Minute Rule doesn’t apply to this code set. Makes sense, right? Yeah, we get it if you’re feeling a little confused. But, before you strike the surrender cobra pose, read through the following advice: per CMS, if a provider spends more than half of his or her time providing skilled therapy to the patient, then it’s appropriate to bill for one unit. But, if the therapist spends less than 50% of his or her specified treatment time with the patient—perhaps because treatment was conducted in a group setting, and the therapist divided his or her time among two or more patients—then he or she couldn’t bill for any units. The latter scenario is similar to when a therapist spends, say, five or six minutes performing a direct-time service under the 8-Minute Rule—and thus could not bill for one unit.

Can therapists apply pseudo-timed code minutes to total direct minutes?

This is where things get a bit hairy. Now, while full-scale industry appreciation of pseudo-timed codes may be limited—and, remember, CMS has yet to formally define these codes—WebPT users are in luck. We’ve incorporated the ones that apply to PTs, OTs, and SLPs within the direct-time code section of the WebPT application. The system will then add the minutes spent performing these services to the number of total treatment minutes, which displays at the top of the billing section.

However—and here’s where reading the fine details really matters—therapists should not (and cannot) include the minutes associated with pseudo-timed codes as part of the total direct minutes for a particular date of service. That’s because, while pseudo-timed codes work in concert with timed codes, Medicare more or less views them as specialized untimed (i.e., service-based) codes—at least for the purposes of billing. Furthermore, Medicare is vague about how providers should go about:

  • billing pseudo-timed codes with direct-time codes on a single claim;
  • applying the 8-Minute Rule to these specialized timed codes; and
  • defining the minute ranges for a single unit of a pseudo-timed code.

Wait, so how do you account for pseudo-timed codes in your billing practices?

As I mentioned above, you can turn to an intuitive EMR like WebPT to ensure your billing practices meet CMS guidelines for pseudo-timed codes. Within the WebPT application, the total number of minutes billed for pseudo-timed codes will be added to the total treatment minutes—similar to an untimed code.


Knowing the ins and outs of all things billing-related can feel overwhelming, but don’t beat yourself over the head with all this pseudo-timed code mumbo-jumbo. Instead, simply keep these pointers handy—you might want to mark this blog as a “favorite” on your browser—and make sure to reference them when trying to up your billing game. Cheers to more dolla dolla bills, y’all.

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