Automated review focused on “excessive units” of untimed therapy has been approved by the Centers for Medicare & Medicaid Services (CMS) for all four Recovery Audit Contractor (RAC) regions. In plain English, this is billing for untimed units numbering greater than one per visit. For example, if a patient received mechanical traction (as indicated in the plan of care) for 23 minutes, only one unit can be billed, as mechanical traction is an untimed, service-based code. The minutes do not count toward timed code treatment minutes; rather, they are tallied in total treatment minutes, as required by Medicare.
Longtime subscribers to RACmonitor may recall my 2009 article on this same topic: it was one of the first automated issues announced when the permanent RACs rolled out: https://www.racmonitor.com/catch-me-if-you-can-staying-ahead-of-the-rac-reviews-of-untimed-codes.
What is more than a bit perplexing about the posting (reissuing) of this CMS-approved issue is the fact that the Medicare Administrative Contractors (MACs) should have long ago instituted payor side edits to prevent the payment of untimed therapy codes that are billed in units greater than one (what they are labeling as “excessive units.”) Providers should know and understand the billing rules, that is a given, and the money should be recouped if units greater than one were billed and paid. But now we are going through a process that demands time from everyone concerned to manage and adjust, because MAC preventive edits were not in place.
Of note, in the 2009 vetting of this automated issue, we reported that therapy providers were getting denials for two separate untimed codes on the same claim, which is permissible (given other coding rules to the contrary). For example, such a scenario would be billing for a physical therapy evaluation (untimed code), and for the same visit billing for unattended electrical stimulation (untimed code). Another problem we noted during one of our first Monitor Mondays broadcasts was automated adjustments by a RAC for two different speech codes, not subject to CCI edits, in the same visit.
Here is how it is framed up by each of the RACs, using the following reference citations:
| RAC | Provider Types | Description |
| Region 1 Performant |
Outpatient Hospital; Part B Professional Services; Outpatient Non-Hospital Facility; Skilled Nursing Facility (SNF); Outpatient Rehab Facility (ORF); Comprehensive Outpatient Rehab Facility (CORF); Physician and Non-Physician Practitioner/Provider Specialty | When reporting service units for untimed codes (excluding Modifiers -KX, and -59), wherein the procedure is not defined by a specific time frame, the provider should enter a “1” in the units billed column, per date of service. |
| Region 2 Cotiviti |
OPH; OP Non-Hospital; SNF; ORF; CORF; Physician | When reporting service units for untimed codes (excluding Modifiers -KX, and -59), wherein the procedure is not defined by a specific time frame, the provider should enter a “1” in the units billed column, per date of service. |
| Region 3 Cotiviti |
OPH; OP Non-Hospital; SNF; ORF; CORF; Physician | When reporting service units for untimed codes (excluding Modifiers -KX, and -59), wherein the procedure is not defined by a specific time frame, the provider should enter a “1” in the units billed column, per date of service. |
| Region 4 HMS |
Critical Access Hospital (CAH); Other Carrier Biller; Other FI Biller; Outpatient Hospital; Part B Professional Services (Physician/Non-Physician Practitioner); Skilled Nursing Facility | When reporting service units for untimed codes (excluding Modifiers -KX, and -59), wherein the procedure is not defined by a specific time frame, the provider should enter a “1” in the units billed column, per date of service. |
This is a great opportunity to update your therapy compliance risk assessment, and given the new posting by the RACs, to frame up an “automated audit” of your facility’s billed untimed codes. In instances wherein two units of an untimed code were billed and paid, review the therapy note, the corresponding claim, and remittance advice to determine the relevant facts: did the provider bill for units greater than one, as noted on the daily note? Did your billing system or clearinghouse scrub the claim and submit the claim appropriately, for one unit of service for an untimed code? Did you receive payments for excess units of untimed codes?
A further reminder for therapy providers is to continue to look for other known areas of concern regarding therapy that have been cited by your MAC, starting with posted probe reviews and Comprehensive Error Rate Testing (CERT) findings. The CERT Task Force has posted guidance for therapy providers than can be found at your MAC’s website. For those 15,000 physical therapists in private practice that received a comparative billing report (CBR) earlier this year, take some time to review your report and determine if your individual analysis with respect to your state and national peer group requires further attention.
A handy reference of my articles for RACmonitor is summarized here: https://nancybeckley.com/racs/rac_articles_by_nancy_beckley/.
They all link back to the source articles at http://racmonitor.com.
Lab Week has arrived! April 20–26 is Laboratory Medical Professionals Week (MLPW)—a time to honor the commitment of these professionals and recognize the critical role
One of the biggest issues I find when working with clinical documentation integrity (CDI) departments is that the hospital clinical revenue cycle remains siloed. Rather
Please log in to your account to comment on this article.
Struggling with ICD-10-CM coding for diabetes and complications? This expert-led webcast clarifies complex combination codes, documentation gaps, and sequencing rules to reduce denials and ensure compliance. Dr. Angela Comfort will provide actionable strategies to accurately link diabetes to complications, improve provider documentation, and optimize reimbursement—helping coders, CDI specialists, and HIM leaders minimize audit risks and strengthen revenue integrity. Don’t miss this chance to master diabetes coding with real-world case studies, key takeaways, and live Q&A!
Uncover critical guidance. Kay Piper provides an interactive review on coding guidelines and more in the AHA’s fourth quarter 2025 ICD-10-CM/PCS Coding Clinic in an easy to access on-demand webcast.
Uncover critical guidance. Kay Piper provides an interactive review on coding guidelines and more in the AHA’s third quarter 2025 ICD-10-CM/PCS Coding Clinic in an easy to access on-demand webcast.
Uncover critical guidance. Kay Piper provides an interactive review on coding guidelines and more in the AHA’s second quarter 2025 ICD-10-CM/PCS Coding Clinic in an easy to access on-demand webcast.
Struggling with CMS’s 3-Day Payment Window? Join compliance expert Michael G. Calahan, PA, MBA, CCO, to master billing restrictions for pre-admission and inter-facility services. Learn how to avoid audit risks, optimize revenue cycle workflows, and ensure compliance across departments. Critical for C-suite leaders, providers, coders, revenue cycle teams, and compliance teams—this webcast delivers actionable strategies to protect reimbursements and meet federal regulations.
Providers face increasing Medicare audits when using skin substitute grafts, leaving many unprepared for claim denials and financial liabilities. Join veteran healthcare attorney Andrew B. Wachler, Esq., in this essential webcast and master the Medicare audit process, learn best practices for compliant billing and documentation, and mitigate fraud and abuse risks. With actionable insights and a live Q&A session, you’ll gain the tools to defend your practice and ensure compliance in this rapidly evolving landscape.
Dr. Ronald Hirsch dives into the basics of Medicare for clinicians to be successful as utilization review professionals. He’ll break down what Medicare does and doesn’t pay for, what services it provides and how hospitals get paid for providing those services – including both inpatient and outpatient. Learn how claims are prepared and how much patients must pay for their care. By attending our webcast, you will gain a new understanding of these issues and be better equipped to talk to patients, to their medical staff, and to their administrative team.
Hospitals face growing challenges in measuring observation metrics due to inconsistencies in classification, payer policies, and benchmarking practices. Join Tiffany Ferguson, LMSW, CMAC, ACM, and Anuja Mohla, DO, FACP, MBA, ACPA-C, CHCQM-PHYADV as they provide critical insights into refining observation metrics. This webcast will address key issues affecting observation data integrity and offer strategies for improving consistency in reporting. You will learn how to define meaningful metrics, clarify commonly misinterpreted terms, and apply best practices for benchmarking, and gain actionable strategies to enhance observation data reliability, mitigate financial risk, and drive better decision-making.
Copyright © 2025 ICD10monitor. Powered by MedLearn Media.
Happy National Doctor’s Day! Learn how to get a complimentary webcast on ‘Decoding Social Admissions’ as a token of our heartfelt appreciation! Click here to learn more →
CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 2 with code CYBER24
