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When Does Therapeutic Exercise Need a Modifier? Decoding 97110 in Chiropractic Practices

In the world of chiropractic coding in the USA, few codes cause more confusion than CPT 97110—the go-to code for therapeutic exercise. While it seems straightforward, incorrect use or omission of appropriate modifiers can lead to denials, audits, or even overpayment recoupment.

If you’re unsure when 97110 needs a modifier, or how to avoid common pitfalls, here’s a deep dive into what every chiropractic coding USA service provider should know.

What Does CPT 97110 Cover?

CPT code 97110 is used to report therapeutic exercises aimed at improving strength, endurance, flexibility, or range of motion. In chiropractic settings, it often applies to active rehab protocols, such as resisted band exercises, core stabilization, or proprioceptive training.

But the key to proper billing isn’t just what you did—it’s how you document it and whether it’s separately identifiable from other services performed the same day.

The Modifier That Matters: Modifier 59 or XE

One of the most frequent errors in chiropractic coding in the USA is billing 97110 alongside spinal manipulation (e.g., 98940–98942) without a modifier.

Why is that a problem?

Payers often consider therapeutic exercise to be inclusive of chiropractic adjustments unless it’s clearly a distinct service. That’s where Modifier 59 (Distinct Procedural Service) or its more specific alternative Modifier XE (Separate Encounter) becomes critical.

Use Modifier 59 or XE when:

  • 97110 is performed in a separate session from the adjustment.
  • The therapeutic exercise targets non-spinal areas, unrelated to the adjusted region.
  • The documentation supports that the patient required distinct clinical care for both.

Without this modifier, the claim may be denied as “inclusive” or “bundled”—even if both services were validly performed.

Documentation: The Hidden Hero

A chiropractic coding USA service provider must emphasize that modifiers alone don’t justify payment—documentation does.

Here’s what insurers want to see:

  • Clear description of exercise type and purpose
  • Measured duration (97110 is a time-based code—1 unit = 15 minutes)
  • Clinical rationale for why the patient needed both chiropractic adjustment and therapeutic exercise
  • Evidence that services were not redundant

The best chiropractic coding service providers create workflows that ensure providers chart this information at the point of care, reducing retroactive documentation issues.

Don’t Mix It Up: 97110 vs. 97140

Another coding error we see is confusing 97110 (therapeutic exercise) with 97140 (manual therapy). While both are rehab-related, they represent very different interventions. Using one in place of the other—or billing both without justification—can create red flags.If you’re ever unsure, your chiropractic coding service provider should offer coder audits or training refreshers to prevent pattern errors.

Final Takeaway

As chiropractic care becomes more integrated with active rehab, using codes like 97110 properly is essential to ensure clean claims and compliant practices. Whether you’re billing Medicare, commercial insurers, or PI cases, modifiers are not optional—they’re strategic tools that must be backed by documentation.

At Instapay Healthcare Services, we act as a trusted chiropractic coding USA service provider, helping clinics maximize revenue while avoiding audit risks. If you're ready to take the guesswork out of billing therapeutic exercise, we're here to support your team with accuracy and expertise.