Understanding Timed and Untimed CPT Codes

Accurate coding requires clinicians to understand whether a Current Procedural Terminology (CPT®) code is timed or untimed and how the applicable time-reporting rules affect the number of units billed. The code descriptor, CPT instructions, and payer policy determine how a service may be reported.

Beginning January 1, 2027, certain speech-language pathology treatment services will transition from CPT code 92507 to new timed treatment codes. This resource explains the general CPT timing principles that apply to those services as well as many other timed CPT codes used by audiologists and speech-language pathologists. For information about the new codes, see New Speech-Language Pathology Treatment Codes.

On this page:

• Timed and Untimed Codes: What’s the Difference
• Understanding “Time” in CPT Codes
• Same-Day Billing Restrictions
• Verifying Payer Requirements
• Resources
• Questions

Timed and Untimed Codes: What’s the Difference?

CPT codes may be designated as timed or untimed. Understanding the distinction is essential for selecting the appropriate code, documenting the service, calculating billable units, and submitting an accurate claim.

The primary distinction between timed and untimed codes is found in the CPT code descriptor:

• A timed code includes a specific time designation, such as “per 15 minutes,” “initial 30 minutes,” or “first hour.”
• An untimed code does not include a specific time designation and is generally reported as a single unit, regardless of the length of the encounter.

Clinicians should review the complete CPT descriptor, associated parenthetical instructions, CPT guidelines, and payer policies before reporting a service. These sources determine what the code represents under their fee schedules, which activities count toward reportable time, whether a minimum time threshold applies, and how many units may be billed.

Timed Codes

Timed CPT codes include a specific time designation in the code descriptor. Common wording includes:

• each 15 minutes;
• initial 30 minutes;
• first hour;
• each additional 15 minutes; or
• each additional 30 minutes.

Examples include:

• 92620, evaluation of central auditory processing, with report; initial 60 minutes; and
• 92605, evaluation for prescription of a nonspeech-generating augmentative and alternative communication device, face-to-face with the patient; first hour.

Because timed codes are tied to a defined period of service, clinicians must document the amount of reportable time and determine whether the applicable time threshold has been met. Depending on the structure of the code family, additional time may be reported through multiple units of the same code or through an associated add-on code.

Timed codes allow clinicians to provide services of varying lengths based on the patient’s needs while accurately reporting the amount of qualifying time furnished.

Untimed Codes

Untimed CPT codes do not specify an amount of time in the code descriptor. They represent a defined service or procedure rather than a particular number of minutes.

Untimed codes are generally reported once per patient, per date of service, even when the amount of time required to perform the service varies. Spending more time performing an untimed service does not ordinarily support reporting additional units of the code.

Examples of untimed codes include:

• 92550, tympanometry and reflex threshold measurements; and
• 92524, behavioral and qualitative analysis of voice and resonance.

Many audiology and speech-language pathology evaluation and treatment codes are untimed.

Clinicians should provide the amount of service that is medically necessary and clinically appropriate for the patient. The duration of an untimed service may vary based on factors such as:

• the patient’s clinical needs and complexity;
• the patient’s ability to participate in or tolerate the procedure;
• the scope of testing or treatment required;
• the need for interpretation and clinical decision-making; and
• the components included in the CPT descriptor.

These variations generally do not change the number of units reported for an untimed code.

Understanding “Time” in CPT Codes

The word “time” is used in several different ways in CPT coding. Understanding the differences can help prevent common billing mistakes.

1. The time associated with valuing a CPT code.
2. The amount and type of time stated in a timed code descriptor.
3. The actual amount of time a clinician spends furnishing a service.

These concepts are related, but they are not interchangeable.

Underlying Time Used in Code Valuation

Most CPT codes—timed and untimed—have underlying time estimates that are considered when the code is valued through the American Medical Association (AMA)/Specialty Society Relative Value Scale Update Committee, commonly called the RUC.

For codes valued through this process, the underlying work is divided into three components:

These time estimates help describe the professional work associated with the service and inform the code’s relative value.

When a code has been valued through the RUC process, the underlying pre-service, intra-service, and post-service time helps describe the total work associated with the procedure. However, those components are not automatically added together when calculating billable time.

Determining Appropriate Time for Untimed Codes

Although untimed CPT codes are not reported according to the number of minutes provided, clinicians are still expected to devote a reasonable and appropriate amount of time to completing the service.

When an untimed code has been valued through the RUC process, its underlying time may reflect the typical work associated with providing the service. Those times are used to help establish Medicare payment values—but they are not billing requirements. Clinicians are not expected to provide the service for an exact number of minutes, and the underlying valuation time should not be treated as either a minimum or maximum session length.

For untimed codes that have not been valued through the RUC process, there may be no nationally established typical time. In either case, the appropriate duration depends on the CPT code descriptor, the patient’s clinical needs, medical necessity, and the clinician’s professional judgment.

When determining how much time is appropriate for an untimed service, clinicians should consider:

• the purpose and scope of the service;
• all components required by the CPT descriptor;
• the complexity of the patient’s condition;
• the patient’s ability to participate and tolerate the service;
• the need for interpretation, decision-making, and reporting; and
• whether the service was completed sufficiently to support reporting the code.

Providing significantly less time than would reasonably be necessary may raise questions about whether the clinician performed the complete service described by the code.

When documenting a service reported with an untimed code, clinicians should ensure that:

• the amount of time spent with the patient was based on individualized clinical needs;
• all required elements of the service were completed;
• the service was medically necessary;
• the work performed is accurately described by the reported code; and
• the documentation supports the full service reported.

Ultimately, the appropriate amount of time for an untimed service is determined by clinical judgment and the requirements of the code, not by a fixed number of minutes.

Examples of Underlying Valuation Times

Examples of underlying times for untimed codes include:

92557, Comprehensive audiometry threshold evaluation and speech recognition

• Pre-service: 3 minutes
• Intra-service: 20 minutes
• Post-service: 5 minutes

92610, Evaluation of oral and pharyngeal swallowing function

• Pre-service: 7 minutes
• Intra-service: 35 minutes
• Post-service: 10 minutes.

These times help inform Medicare valuation but do not establish required service durations. Each code is still reported as one unit, regardless of whether the service takes more or less time than the typical underlying time.

CMS publishes physician work time files annually as part of the Medicare Physician Fee Schedule rulemaking process. Although these times do not establish required service durations, some payers may consider them when assessing whether the time associated with a reported service appears generally consistent with typical clinical practice. Documentation should therefore support both the services performed and the time required based on the patient's individual needs.

Not every CPT code has an underlying valuation time. Some codes have never been reviewed through the RUC process and may be contractor-priced or valued using other methodologies.

Reporting Unusually Long or Short Untimed Services

Although untimed CPT codes are generally reported as a single unit regardless of the time required to furnish the service, there may be rare circumstances in which a service is substantially shorter or longer than typically expected due to the patient's unique clinical needs.

In these exceptional situations, CPT modifiers may be available to indicate that the service differed significantly from what is ordinarily described by the code:

• Modifier -52 (Reduced Services) may be appropriate when a medically necessary service is partially reduced or completed to a lesser extent than described by the CPT code.
• Modifier -22 (Increased Procedural Services) may be appropriate when providing the service requires substantially greater work than is typically required.

These modifiers should be used sparingly and only when supported by clear documentation explaining the clinical circumstances that made the service unusually short or long. Modifier -22 often results in additional payer review, and many payers require supporting documentation before considering additional reimbursement.

Modifiers should not be used to change the intended purpose of a CPT code or to circumvent coding requirements. For example, clinicians should not report a screening by billing an evaluation code with modifier -52 simply because a screening does not meet the purpose of a full evaluation.

These modifiers apply only to untimed CPT codes. They should not be used to bypass the time requirements associated with timed CPT codes.

What Time Counts Toward a Timed Code?

Unless the CPT descriptor or instructions state otherwise, the time designation in a timed code generally refers to intra-service time—the period during which the clinician is directly performing the procedure or providing the service.

Depending on the code descriptor, this may be described as face-to-face time, direct one-on-one treatment, or another specifically defined type of professional time.

Pre-Service and Post-Service Activities

Pre-service and post-service activities may be included in the overall work associated with the code, particularly when the code was valued through the RUC process. However, this time generally may not be counted toward the time threshold for reporting the timed service unless the descriptor or CPT instructions specifically allow it.

Examples of time that generally should not be added to direct service time include:

• reviewing the medical record before the encounter;
• preparing materials or equipment;
• completing routine documentation after the service;
• coordinating care after the encounter; and
• educating the family/caregiver and communicating with health care professionals outside the period described by the code.

Interpretation and Report

The inclusion of the phrase “interpretation and report” in a code descriptor does not mean that all documentation time may be counted toward the billable time reported under a timed code. Generally, interpretation and report time may be counted only when it is directly related to interpreting test results and preparing the associated report. Routine documentation, such as updating the plan of care or completing session notes, generally does not count toward reportable time.

Examples of codes that include reportable “interpretation and report” in billable time include:

• 92615: Standardized cognitive performance testing (eg, Ross Information Processing Assessment) per hour of a qualified health care professional’s time, both face-to-face time administering tests to the patient and time interpreting these test results and preparing the report
• 92548: Computerized dynamic posturography sensory organization test (CDP-SOT), 6 conditions (ie, eyes open, eyes closed, visual sway, platform sway, eyes closed platform sway, platform and visual sway), including interpretation and report

Understanding Time Thresholds

Each timed CPT code has a minimum time threshold that must be met before the service may be reported. The CPT midpoint rule and Medicare’s 8-mintue rule are different methodologies. Although they may produce the same result in some situations, they are separate methodologies and should not be used interchangeably. Other payers may follow Medicare’s rule, apply the CPT midpoint rule, or establish their own requirements.

Midpoint Rule

Many timed codes follow the midpoint rule, sometimes called the 51% rule. Under this rule, a unit of time is reached once more than half of the reportable time stated in the code descriptor has elapsed.

For example:

• A 60-minute service reaches one reportable unit after 31 minutes have elapsed.
• A second 60-minute unit is reached after a total of 91 minutes have elapsed.

The same principle generally applies to other time increments when the midpoint rule is permitted.

For a 15-minute timed service, for example:

• 0–7 minutes generally would not support one unit;
• 8–22 minutes may support one unit; and
• 23–37 minutes may support two units.

The midpoint rule does not apply universally. The CPT descriptor, parenthetical instructions, code-specific guidance, or payer policy may modify the standard rule or require completion of the full amount of time stated in the descriptor.

For example, Medicare requires caregiver training services reported with CPT codes 97550 and 97551 to be provided face-to-face with the caregiver, without the patient present, for the full time specified in the descriptor. However, other payers may still follow the established CPT midpoint rule for the same codes.

Clinicians should review the complete CPT instructions and applicable payer policies before determining whether the midpoint rule applies.

Medicare’s 8-Minute Rule

Medicare Part B uses a separate methodology, commonly called the 8-minute rule, for certain therapy services reported in 15-minute increments, including applicable physical therapy, occupational therapy, and speech-language pathology services.

Under this methodology:

• At least 8 minutes of qualifying direct treatment must be provided before one 15-minute unit may be reported.
• Additional units are determined based on the total qualifying timed treatment minutes provided during the encounter.

Note: Medicare’s 8-minute rule only applies to 15-minute timed codes.

Reporting Base and Add-On Codes

Some timed CPT codes are structured as a base code and one or more add-on codes. This structure allows clinicians to report an initial period of service and additional time when the patient’s needs require a longer encounter.

Base Codes

A base code represents the primary service and the initial time associated with that service. Its descriptor may include language such as:

• “initial 15 minutes”;
• “initial 30 minutes”; or
• “first hour.”

A base code is typically reported once for the same patient and date of service.

Add-On Codes

An add-on code represents additional intra-service work and time beyond the period described by the base code. Add-on codes:

• are identified by a + (plus) symbol in the CPT code set;
• commonly include language such as “each additional”;
• include instructions identifying the base code with which they may be reported;
• may not be reported as stand-alone services; and
• may not be reported with an unrelated base code.

Before an add-on code may be reported, the clinician generally must complete the full amount of time represented by the base code. Time used to complete the base period cannot also be counted toward the add-on period.

When the midpoint rule applies:

• the midpoint rule may be used to report the base code when only the base code is billed;
• the full base code period must be completed before time begins to accrue toward an add-on code;
• the midpoint rule may be applied to a single add-on unit;
• when multiple add-on units are reported, the full time must be completed for each intervening unit; and
• the midpoint rule may be applied to the final add-on unit.

Code-specific CPT instructions and payer policies may establish different requirements.

Example

A clinician provides 55 minutes of cognitive function intervention during a single treatment session.

Coding:

• 97129 × 1 (initial 15 minutes)
• 97130 × 2 (each additional 15 minutes)

Why?

• The clinician first completes the full 15 minutes required to report the base code (97129).
• The next 15 minutes are reported with one unit of the add-on code (97130).
• After a total of 45 minutes has been furnished (15-minute base code + two full 15-minute intervals), the remaining 10 minutes exceed the midpoint of the next 15-minute interval. Therefore, a second unit of 97130 may be reported.

If the same treatment session lasted 48 minutes, the clinician would report:

• 97129 × 1
• 97130 × 1

Because only 3 minutes remain after the first add-on code, the midpoint of the next 15-minute interval has not been reached, so a second unit of 97130 cannot be reported.

Reporting More Than One Base Code

Two separate base codes may sometimes be reported during the same encounter when distinct services are provided. Each service must independently meet:

• the applicable CPT descriptor;
• its minimum time requirement;
• medical necessity requirements;
• documentation requirements; and
• any applicable same-day billing or payer rules.

Time used to support one timed code cannot also be used to support another code describing a distinct and separate procedure or service.

Keeping Track of Time When Multiple Services Are Provided

Clinicians may provide more than one service during the same encounter, including:

• two or more timed services;
• a timed and an untimed service;
• services represented by separate base codes; or
• treatment addressing multiple disorder areas.

The time associated with each separately reported timed service should be tracked and documented.

Example

A clinician provides:

• 30 minutes of cognitive function intervention (CPT codes 97129 for the initial 15 minutes of treatment and 97130 for each additional 15 minutes of treatment)
• 20 minutes of swallowing treatment (CPT code 92526)

Because 97129 and 97130 are timed codes and 92526 is an untimed code, the clinician must separately track the time spent providing the cognitive intervention. The time devoted to the swallowing treatment cannot be counted toward the time reported for 97129 and 97130. Documentation should clearly identify the services provided, the time spent on cognitive intervention, and the medical necessity for reporting both services.

Coding:

• 97129 × 2 units (30 minutes of cognitive function intervention)
• 92526 × 1 unit (swallowing treatment)

The timed service (97129 and 97130) is reported based on the applicable time-based billing methodology, while the untimed service (92526) is reported once per date of service, regardless of the total time spent furnishing the swallowing treatment.

The same time period cannot be counted toward more than one timed CPT code. When another service is performed during a timed service, the time associated with the other service should not be included in the time used to report the timed code.

Similarly, when a timed and an untimed service are provided during the same encounter, time devoted to the untimed service should not be counted toward the timed code.

When treatment addresses multiple disorder areas, documentation should reasonably identify:

• the areas addressed;
• the interventions, procedures, or activities performed;
• the time devoted to each separately reported timed service; and
• how the services relate to the patient’s goals and plan of care.

Clinicians may make a reasonable estimate of the time devoted to each treatment component when activities are clinically integrated and precise minute-by-minute tracking is not practical. The allocation should accurately reflect the services provided and should not include overlapping or duplicated time.

Documentation for Timed Services

Documentation for timed services should generally include:

• the total reportable time;
• start and stop times when required by the payer, facility, or organizational policy;
• the interventions, procedures, or activities performed;
• the time devoted to each service when multiple timed codes are reported; and
• sufficient clinical detail to support the codes and units billed.

Start and stop times alone may not be sufficient. The record should also explain what services were provided and how the reported time was used.

Example

One possible documentation structure is:

Total direct treatment time was [number] minutes. Treatment addressed [clinical area or service] through [brief description of interventions or activities]. Patient and/or caregiver education included [topic, strategy, or recommendation].

When more than one timed service is reported, the documentation may separately identify the time devoted to each service:

Total direct treatment time was [number] minutes, including [number] minutes addressing [service or clinical area] and [number] minutes addressing [second service or clinical area].

Documentation should always be individualized to the patient and the services provided.

Before submitting the claim, clinicians should compare the documented time with:

• the applicable billing methodology;
• the number of units entered on the claim; and
• the base and add-on codes reported.

The documented minutes, units, and code structure should be consistent.

Use of Modifiers With Timed Codes

The -22 modifier for increased procedural services and the -52 modifier for reduced services cannot be  used with a timed code. Specifically, these modifiers cannot be used to:

• bypass a minimum time threshold;
• report a service when insufficient qualifying time was provided;
• compensate for completing only part of the service described by the code; or
• report additional units when the required time was not furnished.

However, other modifiers may be required to provide additional information about a service. Depending on the code, setting, and payer. Examples of modifiers that may be used with timed codes include:

• discipline-specific modifiers, such as -GN;
• laterality modifiers, such as -RT or -LT; and
• other modifiers required by a payer or program.

Modifiers should be used only when supported by the service provided and permitted by the payer.

Same-Day Billing Restrictions

Clinicians should be aware that Medicare and Medicaid coding edits may restrict certain CPT or HCPCS code combinations reported for the same patient on the same date of service. Unit limits may also affect how many times a code may be reported.

Commercial health plans may adopt Medicare or Medicaid coding edits or establish their own requirements. Clinicians should review the applicable payer policy before reporting multiple services or units on the same date of service.

For more detailed information, see ASHA’s resources on National Correct Coding Initiative (NCCI) System for Audiology and Speech-Language Pathology Services.

The CCI edit system also includes Medically Unlikely Edits (MUEs) for Medicare Part B and Medicaid claims. An MUE identifies the maximum number of units of a procedure code that would generally be expected for the same patient on the same date of service. Untimed codes typically have an MUE of 1, while timed codes may have a higher MUE because multiple units may be reported to reflect the time spent providing the service. Not all CPT codes have an MUE. Chapter 1 of the NCCI Policy Manual provides additional guidance.

Verifying Payer Requirements

CPT provides a common coding framework, but coverage, billing, and payment policies may vary among Medicare, Medicaid programs, and commercial health plans.

Before submitting a claim for a timed service, clinicians should confirm:

• whether the payer recognizes and covers the code;
• which time calculation methodology applies;
• which activities count toward reportable time;
• whether the full amount of time in the descriptor must be completed;
• whether start and stop times are required;
• how base and add-on codes should be reported;
• whether same-day billing restrictions apply;
• which modifiers are required; and
• whether the payer has additional documentation or authorization requirements.

Clinicians remain responsible for ensuring that the claim accurately reflects the service provided and complies with applicable coding and billing requirements.

Resources

• The Right Time for Billing Codes ASHA Leader article
• Medicare CPT Coding Rules for Audiology Services
• Medicare CPT Coding Rules for Speech-Language Pathology Services
• National Correct Coding Initiative (NCCI) System for Audiology and Speech-Language Pathology Services
• Medically Unlikely Edits for Audiology Services
• Medically Unlikely Edits for Speech-Language Pathology Services

Questions?

Please contact reimbursement@asha.org.