Therapy Billing Units Allocator: CMS 8-Minute Rule vs. AMA + CQ/CO Check
Pool mixed remainders across multiple 15-minute timed CPT codes, compare against per-code AMA midpoint billing, and flag mandatory CQ/CO assistant modifiers.
CMS Pooled 8-Minute Ladder vs. AMA Per-Code Rule of Eights
Medicare sums all timed one-on-one CPT minutes first (8–22m = 1u, 23–37m = 2u, 38–52m = 3u, 53–67m = 4u), whereas AMA commercial payers evaluate whether each individual code reached 8 minutes independently (so 8 min of 97110 + 8 min of 97140 = 1 unit on Medicare vs. 2 units on AMA contracts).
KX modifier threshold: have you crossed $2,480 this year?
For CY 2026 the KX threshold is $2,480 for PT and SLP combined and $2,480 separately for OT (CMS Therapy Services CY 2026 update; re-confirmed at each November re-check). Crossing it is not a cap and not permission: append KX only on claims where continued therapy is medically necessary and the record documents it. The year-to-date fields in the allocator above run this check on every calculation.
Frequently Asked Billing Questions
When do CQ or CO modifiers apply to outpatient physical or occupational therapy?
Under CMS MM12397, when a PTA or OTA furnishes more than 10% of a service unit independently of the therapist, append CQ (PT) or CO (OT); Medicare pays 85% of the fee schedule.
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