ATU Resources · Medicare and Billing

Medicare Coverage for Aquatic Therapy: What Each Contractor Says

Which Medicare contractors have written rules on aquatic therapy and code 97113, what those rules ask you to document, and how to check your own contractor.

Published by ATU Educational Services, LLCLast reviewed October 23, 2026An 8–10 minute read, plus the checklists

Important: Please read before you use this page

This page is general educational information only. It is not legal, billing, coding, reimbursement or medical advice.

Rules change and differ by region. Medicare rules, and the local rules that each Medicare Administrative Contractor (MAC) publishes, change often and are not the same in every region. They may have changed since this page was last reviewed.
Check current sources before you act. Always confirm with current official sources, such as Medicare.gov, the Centers for Medicare & Medicaid Services (CMS) Medicare Coverage Database and your own Medicare contractor, and with your own billing and compliance staff.
No guarantee. Nothing here guarantees coverage or payment for any service or claim.
You make the decisions. ATU Educational Services, LLC and its authors are not responsible for decisions made, or claims filed, based on this information.
Independent. ATU Educational Services, LLC is not affiliated with or endorsed by CMS or any Medicare Administrative Contractor.

Last reviewed October 23, 2026

Short answer
National rules
By contractor
What they ask for
Documentation check
Find your rules
Retired rules
Questions
Ask us

The short answer

Medicare pays for each claim through a regional company called a Medicare Administrative Contractor (MAC). Each MAC can publish a Local Coverage Determination (LCD), which says when a service is reasonable and necessary, and a Local Coverage Article (LCA), which explains billing and coding. Aquatic therapy is billed with Current Procedural Terminology (CPT) code 97113 in every state.

National rules that apply in every state

Chapter 15 of the Medicare Benefit Policy Manual applies no matter who your MAC is. For therapy in a community pool, it says the practice or provider “shall rent or lease the pool, or a specific portion of the pool” for the use of its own patients during set times.¹ Section 220.1 A points back to these pool rules for aquatic therapy.¹

The same chapter’s general therapy rules apply in the water too: services must need the skills of a therapist, be reasonable and necessary, and follow a certified plan of care.¹

What each contractor says now

Jurisdictions are listed by the letter-and-number names CMS uses for Part A and Part B claims. Click a document number to see its full reference and link.

Jurisdiction	Contractor	Current written language on aquatic therapy	Documents
All	All contractors	National pool rules apply everywhere	Benefit Policy Manual ch. 15 §220 C
JE, JF	Noridian	Yes. Skilled water-based therapy needs direct one-on-one contact with the clinician the whole time	A53304
JJ, JM	Palmetto GBA	Yes, for Part A. Full aquatic therapy sections. For Part B, aquatic therapy is mentioned only in a pain-injection document	L34428, L34427, A53065
J6, JK	Wellpoint Federal, formerly National Government Services	Yes. Full aquatic therapy and 97113 sections	L33631, A56566
J15	CGS	Yes. Full aquatic therapy sections, including home health	L34049, A57067, L33942
J5, J8	WPS	Mentions only. Aquatic therapy is named as conservative care in joint replacement and pain-injection documents. An older aquatic therapy rule from before 2015 is archived and cannot be opened	L39911, L40300
JH, JL	Novitas	None current. A full aquatic therapy section was retired March 1, 2023	L35036, retired
JN	First Coast	None current. A full aquatic therapy section was retired March 1, 2023	L33413, retired

“Mentions only” means the contractor names aquatic therapy, but in a document about another treatment, such as joint replacement, rather than in rules for aquatic therapy itself. Palmetto’s aquatic therapy documents list Part A contractor numbers only.

Business consulting

Setting up Medicare billing for a pool program?

Starting aquatic therapy, moving to a new pool or preparing for a review? Getting the setup right at the start saves denials later.

Aquatic Therapy University offers business consulting for aquatic therapy programs. We can help with:

Medicare and billing setup for aquatic therapy
Finding and reading your contractor’s current rules
Pool rental agreements that meet the Medicare rules
Documentation templates and staff training
Program business planning and launch

We offer business consulting only. We do not design or build pools, and we do not give legal advice or submit claims. To ask about consulting, call 865-204-0618, email info@swimatu.com or use the Contact Us form on our Private Training page.

Call 865-204-0618 Email us Send a message

What the contractor documents ask for

Where MACs have written rules, they agree on most points:

Why water, not land

Aquatic therapy may be reasonable and necessary when a patient cannot tolerate land-based exercise for rehabilitation.^6,8 Palmetto says it is important to document the need for water rather than land.³

Skilled, one-on-one time

Count only skilled exercise time with direct one-on-one contact. Do not count dressing, undressing, or getting into and out of the pool.^8,2

A path back to land

Aquatic exercise should help the patient move on to land-based therapy and better function, or to a home or community program.^6,8

Two more points are common. Water exercise for general fitness, flexibility, endurance or weight loss is not covered.^6,8 And once a patient can do an exercise safely on their own, the time spent repeating it is no longer billable as skilled therapy.^6,8 Palmetto also says to use 97113 when teaching a patient aquatic exercises to do on their own in a community pool.⁵

Documentation check for aquatic therapy

Each point below comes from the contractor documents cited above. Use it to review a note before you sign it.

Why the water
The note says why the patient needs water rather than land, such as being unable to tolerate land-based exercise.
Objective limits are recorded: mobility, range of motion, strength, balance, pain or function.
What you did
The specific exercises and how they progressed are listed.
The note shows what the therapist’s skill added, beyond supervising exercise the patient can do alone.
Minutes counted are skilled one-on-one minutes only, not dressing, changing or pool entry and exit.
The water modality, such as a whirlpool, is not billed on top of aquatic therapy.
Where it is going
The plan says how the patient will move to land-based exercise, or to a home or community program.
Fitness or wellness exercise is kept out of the billed minutes.
The pool
If you treat in a community pool, the written rental or lease agreement is on file and covers your times and space.

Your checks stay on this device only. Nothing is sent to us.

How to find your contractor’s current rules

Find your contractor’s rules

Expert opinion

Documents change often. Work through these steps at least once a year, and before a new program or an audit.

Confirm which MAC handles claims for your state and for your claim type: Part A, Part B or home health.
Open the Medicare Coverage Database search and search for “aquatic” and “97113”.
Search both LCDs and articles. Billing details are often only in the article.
Check that your contractor number is listed on the document, not just your state.
Note the version number and effective date, and save a dated copy in your compliance file.
Read your contractor’s general therapy LCD or article as well, even if it does not mention water.
Set a reminder to check again in six to 12 months.

Your checks stay on this device only. Nothing is sent to us.

Retired and older rules

Several contractors that have no aquatic therapy rules today had them in the past. Retired documents are no longer in force, but they explain what older articles, courses and auditors may still quote.

Novitas, jurisdictions JH and JL: said aquatic therapy may be reasonable and necessary when the patient cannot do land-based exercise effectively without it first, or when it helps the patient move on to land-based exercise. Retired March 1, 2023.¹³
First Coast, jurisdiction JN: listed conditions under which aquatic therapy with therapeutic exercise may be medically necessary. Retired March 1, 2023.¹⁴
Cahaba, former Part B contractor in jurisdiction JJ: had a 97113 section, including that lack of a pool at home does not make continued clinic treatment skilled. Retired January 28, 2018, when Palmetto took over.¹⁵
WPS, jurisdictions J5 and J8: had an outpatient therapy LCD with a 97113 section before 2015. CMS now lists it as permanently archived, and its text cannot be opened, so we do not quote it here.

Questions

Does every Medicare contractor have an aquatic therapy LCD?

No, but every contractor is covered by something. The national Medicare Benefit Policy Manual sets pool rules for everyone.¹ Noridian, Palmetto for Part A, Wellpoint Federal and CGS have current written rules on aquatic therapy. WPS mentions aquatic therapy in documents about other treatments. Novitas and First Coast retired their aquatic therapy sections on March 1, 2023.^13,14

Does the therapist have to be in the water?

Not always. Wellpoint Federal and CGS say the clinician does not need to be in the water unless there is an identified safety issue.^6,8 Noridian says skilled water-based therapy needs direct one-on-one contact with the clinician throughout the procedure.² Either way, count only skilled one-on-one minutes.

Can we bill 97113 for therapy in a community pool?

Yes, if the national rules are met. The practice or provider must rent or lease the pool, or a specific part of it, for its own patients at set times, and keep the written agreement.¹ See our page on renting a pool for therapy.

Our contractor has no aquatic therapy document. What rules apply?

The national rules in the Medicare Benefit Policy Manual, chapter 15, plus your contractor’s general therapy rules.¹ The service must be skilled, reasonable and necessary, and on a plan of care. Many clinics also use the reasoning in other contractors’ documents as a guide to good notes. That is a sensible habit, but those documents do not bind your contractor.

Are retired documents still in force?

No. A retired LCD or article no longer applies. We list them because they show what those contractors expected, and because older articles and courses still quote them.

Can we bill for time spent getting in and out of the pool?

No, according to CGS and Wellpoint Federal. Count only skilled exercise time that needed direct one-on-one contact. Do not count time to dress, undress, or get into and out of the pool.⁸

Is a water fitness or wellness class covered as aquatic therapy?

No. Wellpoint Federal and CGS say water exercise to promote overall fitness, flexibility, endurance, aerobic conditioning or weight loss is not covered.^6,8 Keep fitness classes and therapy separate in your schedule, notes and billing.

How often do these documents change?

Often. Several documents on this page were revised in 2026. Check the Medicare Coverage Database before an audit, a new program or a staff training.¹⁶

Can Aquatic Therapy University set up our Medicare billing?

We offer business consulting for aquatic therapy programs, including Medicare and billing setup. We are not lawyers or billing auditors, and we do not submit claims for you. Ask us about consulting.

Have a Medicare question about your pool program?

Ask us. Tell us what you are setting up, such as a new aquatic program, a move to a rented pool or training your team on documentation, and we will point you to what fits: a course, private training for your team or business consulting for your program.

Call 865-204-0618, email info@swimatu.com, or use the Contact Us form on our Private Training page.

Call 865-204-0618 Email us Send a message

References

Every source cited on this page, in American Medical Association style. Each link goes to the official Centers for Medicare & Medicaid Services copy.

Centers for Medicare & Medicaid Services. Medicare Benefit Policy Manual, Chapter 15: Covered Medical and Other Health Services, sections 220 C and 220.1 A (Revision 13889, issued July 30, 2026). Accessed October 23, 2026. cms.gov (PDF).
Noridian Healthcare Solutions. Billing and Coding: Medical Necessity of Therapy Services. Article A53304, version 16, effective October 2, 2025. Medicare Coverage Database. Accessed October 23, 2026. cms.gov.
Palmetto GBA. Outpatient Physical Therapy. Local Coverage Determination L34428, version 93, effective May 18, 2023. Medicare Coverage Database. Accessed October 23, 2026. cms.gov.
Palmetto GBA. Outpatient Occupational Therapy. Local Coverage Determination L34427, version 100, effective April 13, 2023. Medicare Coverage Database. Accessed October 23, 2026. cms.gov.
Palmetto GBA. Billing and Coding: Outpatient Physical Therapy. Article A53065, version 80, effective October 1, 2026. Medicare Coverage Database. Accessed October 23, 2026. cms.gov.
Wellpoint Federal. Outpatient Physical and Occupational Therapy Services. Local Coverage Determination L33631, version 52, effective April 1, 2026. Medicare Coverage Database. Accessed October 23, 2026. cms.gov.
Wellpoint Federal. Billing and Coding: Outpatient Physical and Occupational Therapy Services. Article A56566, version 46, effective April 1, 2026. Medicare Coverage Database. Accessed October 23, 2026. cms.gov.
CGS Administrators. Outpatient Physical and Occupational Therapy Services. Local Coverage Determination L34049, version 36, effective June 4, 2026. Medicare Coverage Database. Accessed October 23, 2026. cms.gov.
CGS Administrators. Billing and Coding: Outpatient Physical and Occupational Therapy Services. Article A57067, version 34, effective June 4, 2026. Medicare Coverage Database. Accessed October 23, 2026. cms.gov.
CGS Administrators. Physical Therapy - Home Health. Local Coverage Determination L33942, version 50, effective August 6, 2026. Medicare Coverage Database. Accessed October 23, 2026. cms.gov.
Wisconsin Physicians Service Insurance Corporation. Total Joint Arthroplasty. Local Coverage Determination L39911, version 10, effective August 27, 2026. Medicare Coverage Database. Accessed October 23, 2026. cms.gov.
Wisconsin Physicians Service Insurance Corporation. Peripheral Nerve Injections and Procedures for Chronic Pain. Local Coverage Determination L40300, version 8, effective October 25, 2026. Medicare Coverage Database. Accessed October 23, 2026. cms.gov.
Novitas Solutions. Therapy and Rehabilitation Services (PT, OT). Local Coverage Determination L35036, version 119; retired March 1, 2023. Medicare Coverage Database Archive. Accessed October 23, 2026. cms.gov archive.
First Coast Service Options. Therapy and Rehabilitation Services. Local Coverage Determination L33413, version 46; retired March 1, 2023. Medicare Coverage Database Archive. Accessed October 23, 2026. cms.gov archive.
Cahaba Government Benefit Administrators. Medicine: Physical Therapy - Outpatient. Local Coverage Determination L34310, version 16; retired January 28, 2018. Medicare Coverage Database Archive. Accessed October 23, 2026. cms.gov archive.
Centers for Medicare & Medicaid Services. Medicare Coverage Database: search. Accessed October 23, 2026. cms.gov.

How to cite this page

Last reviewed October 23, 2026 · Permanent URL: https://www.aquatictherapyuniversity.com/medicare-coverage-for-aquatic-therapy

How to cite (American Psychological Association style)

Salzman, A. (Ed.). (2026, October 23). Medicare coverage for aquatic therapy: What each contractor says. Aquatic Therapy University; ATU Educational Services, LLC. https://www.aquatictherapyuniversity.com/medicare-coverage-for-aquatic-therapy

Date reviewed: October 23, 2026. Outside sources were checked on October 23, 2026 and may have changed since then. Cite the date you accessed this page, because content may change.

Permissions: You may quote and cite this page with attribution, and print the checklists for your own practice. Reproducing or adapting the page, or any substantial part of it, requires written permission from ATU Educational Services, LLC.

Copyright: © 2026 ATU Educational Services, LLC. All rights reserved. Free to read, quote and cite with attribution; copying, republishing, adapting or selling the page or its content requires written permission. Quoted Medicare documents are U.S. government works.

Editor: Andrea Salzman, MS, PT · ORCID: https://orcid.org/0009-0009-5255-7074

Competing interests: ATU Educational Services, LLC publishes this page and sells aquatic therapy continuing education, private training and business consulting, which this page links to. The “Find your contractor’s rules” steps come from its experience and are labeled Expert opinion. This page does not sell, rank or recommend any billing company, consultant or product.

This page was drafted with AI assistance under the editorial direction of ATU Educational Services, LLC, checked against its cited sources, and corrected when errors are reported. Report errors to info@swimatu.com.

Disclaimer: This page is general educational information only, not legal, billing or medical advice. Rules change; check current official Medicare sources. Last reviewed October 23, 2026. Full disclaimer