Modifier -CQ: PT Services Furnished In Whole or In Part by a Physical Therapist Assistant

Quick reference

  • What it signals: -CQ identifies that a physical therapy service was furnished in whole or in part by a Physical Therapist Assistant (PTA) — not the supervising Physical Therapist (PT).
  • Mandatory for Medicare Part B: Effective January 1, 2020, CMS requires -CQ on any PT claim line where a PTA participated in furnishing that service. Failure to append it is a compliance violation.
  • 15% payment reduction triggered: Appending -CQ to a CPT line automatically triggers a 15% reduction in Medicare reimbursement for that specific line. The reduction applies line-by-line, not claim-wide.
  • Companion modifier -CO: -CO is the equivalent modifier for Occupational Therapist Assistants (OTAs); -CQ is PT only.

Core Medicare/CMS rules (high yield)

  • “In whole or in part” standard: If a PTA furnishes any portion of the service on that line, -CQ is required — unless the de minimis exception applies (see below).
  • De minimis / ≥8-minute rule exception: If the supervising PT personally furnishes ≥8 minutes of the last billable unit of a timed service, that unit may be billed without -CQ, even if the PTA participated in earlier units on the same date. CMS confirmed this in the CY 2022 Physician Fee Schedule Final Rule.
  • Paired with therapy discipline modifier: -CQ is always used in addition to — not instead of — the -GP modifier (physical therapy plan of care). The line will carry both -GP and -CQ.
  • Untimed codes: -CQ applies to untimed procedure codes as well when a PTA furnished the service in whole.
  • Joint treatment: If the PT and PTA provide the full treatment together for the entire session, -CQ is not applied — the service is considered provided by the PT.

Documentation checklist (what to show)

  • Identify who performed each unit: Therapy notes must clearly document which clinician (PT vs. PTA) performed each timed unit. This is critical for the de minimis analysis.
  • Total time per clinician: Record both PT and PTA minutes per CPT code on each date of service.
  • Plan of care: The supervising PT must have an established, active plan of care (-GP) on file. The PTA operates under this plan.
  • Supervision level documented: Document that the required level of supervision (direct or general, per setting) was maintained.

Common CPT codes billed with -CQ (Medicare PT context)

  • Therapeutic exercise: 97110 (Therapeutic exercises) — most frequently billed PT code with -CQ.
  • Therapeutic activities: 97530 (Therapeutic activities) with -CQ.
  • Neuromuscular reeducation: 97112 with -CQ.
  • Gait training: 97116 with -CQ.
  • Manual therapy: 97140 with -CQ.
  • Self-care/home management: 97535 with -CQ.
  • Aquatic therapy: 97113 with -CQ.
  • All of the above also carry -GP on the same line.

Billing line example

DateCPTModifiersUnitsNote
MM/DD/YYYY97110-GP -CQ2PTA performed; 15% reduction applies
MM/DD/YYYY97530-GP1PT personally performed ≥8 min last unit; no CQ

Payer considerations

  • Medicare: -CQ is mandatory; missing modifier = compliance risk and potential overpayment. 15% reduction is applied per line.
  • Commercial payers (BCBS, UHC, Aetna, Cigna): Not all commercial payers require -CQ or apply the 15% reduction — verify individual payer contracts. Many follow Medicare but some do not have a PTA differential.
  • Medicaid: Varies by state. Confirm your state Medicaid fee schedule for PTA differential policies.

Quick self-check (before you append -CQ)

  1. Did a PTA furnish the service in whole or in part (and the de minimis exception does not apply)?
  2. Is -GP also on the same claim line?
  3. Is there documentation of PT minutes vs. PTA minutes per timed unit to support the de minimis analysis?
  4. Is this a Medicare or payer that requires -CQ?