Time Unit Borrowing
CMS has recently clarified the 8 minute rule in Transmittal 1019. The rule clarifies that providers may always bill for one unit of service for every 15 minutes of timed services provided even if some of the services would not normally generate a full unit of service with 8 minute rounding.
An example excerpted from Transmittal 1019 follows:
33 minutes of Therapeutic Exercise (97110),
7 minutes of Manual Therapy (97140),
40 Total Timed Minutes
Appropriate billing for 40 minutes is for 3 units. Bill 2 units of 97110 and 1 unit of 97140. Count the first 30 minutes of 97110 as two full units. Compare the remaining time for 97110 (33-30 = 3 minutes) to the time spent on 97140 (7 minutes) and bill the larger, which is 97140.
In effect, this allows borrowing from timed procedures with excess minutes to be used by other timed procedures. This will always result in the allowance of one unit of timed procedures for every 15 minutes spent on timed procedures. Details may be found beginning on Page 9 of CMS Transmittal 1019: https://www.cms.hhs.gov/transmittals/downloads/R1019CP.pdf