Medicare outpatient therapy documentation: progress reports, treatment notes, and discharge notes

Medicare’s Benefit Policy Manual, Chapter 15, section 220.3, sets the minimum documentation for outpatient physical therapy, occupational therapy, and speech-language pathology. A progress report is due at least once every 10 treatment days and must be written by the clinician, not an assistant. A treatment note is required for every treatment day. A discharge note is required for each episode. The manual says these are minimums; state law, employers, and professional guidelines may require more.

Quoted from official pages checked November 10, 2026. Confirm current requirements, fees, and dates on those sites. This page is not legal advice and does not guarantee eligibility, certification, or licensure.

Source: the Medicare Benefit Policy Manual, Chapter 15, section 220.3, “Documentation Requirements for Therapy Services” (Rev. 255, issued January 25, 2019, effective January 1, 2019), read on November 10, 2026. The plan of care, certification, and recertification are covered on Medicare therapy plans of care and are not repeated here.

What the manual requires

Section 220.3 A states: “Documentation must be legible, relevant and sufficient to justify the services billed.” It also states: “State or local laws and policies, or the policies or professional guidelines of the relevant profession, the practice, or the facility may be more stringent.”

Section 220.3 B lists the expected documents, including “Progress Reports (including Discharge Notes, if applicable) when records are requested after the reports are due” and “Treatment notes for each treatment day (may also serve as progress reports when required information is included in the notes)”. It states: “The timelines are minimum requirements for Medicare payment. Document as often as the clinician’s judgment dictates but no less than the frequency required in Medicare policy”. On dictation: “For Medicare purposes, dictated therapy documentation is considered completed on the day it was dictated.”

Progress reports

Section 220.3 D states: “The progress report provides justification for the medical necessity of treatment.” On who writes it, the manual says the information required in progress reports “shall be written by a clinician that is, either the physician/NPP who provides or supervises the services, or by the therapist who provides the services and supervises an assistant.” It adds: “It is not required that the referring or supervising physician/NPP sign the progress reports written by a PT, OT or SLP.”

On timing: “The minimum progress report period shall be at least once every 10 treatment days.” And: “Regardless of the date on which the report is actually written (and dated), the end of the progress report period is either a date chosen by the clinician or the 10th treatment day, whichever is shorter.” The manual also states: “It should be emphasized that the dates for recertification of plans of care do not affect the dates for required progress reports.”

On absences, it states: “Days on which a patient does not encounter qualified professional or qualified personnel for treatment, evaluation or re-evaluation do not count as treatment days.” On late reports: “If the clinician has not written a progress report before the end of the progress reporting period, it shall be written within 7 calendar days after the end of the reporting period.”

A separate progress report is not always needed. The manual states: “If each element required in a progress report is included in the treatment notes at least once during the progress report period, then a separate progress report is not required.”

Assistants and progress reports

The manual states: “PTAs or OTAs may write elements of the progress report dated between clinician reports. Reports written by assistants are not complete progress reports. The clinician must write a progress report during each progress report period regardless of whether the assistant writes other reports.” It also states: “Note that assistants may not make clinical judgments about why progress was or was not made, but may report the progress objectively.” And: “Assistants may change goals only under the direction of a clinician.”

Treatment notes

Section 220.3 E states: “Documentation is required for every treatment day, and every therapy service.” It states: “The treatment note is not required to document the medical necessity or appropriateness of the ongoing therapy services.” The required elements are the “Date of treatment”, identification of each specific intervention or modality provided and billed, “Total timed code treatment minutes and total treatment time in minutes”, and the “Signature and professional identification of the qualified professional who furnished or supervised the services and a list of each person who contributed to that treatment”.

On supervisor signatures, it states: “The signature and identification of the supervisor need not be on each treatment note, unless the supervisor actively participated in the treatment.”

Discharge notes

The manual states: “The Discharge Note (or Discharge Summary) is required for each episode of outpatient treatment.” It states: “The discharge note shall be a progress report written by a clinician, and shall cover the reporting period from the last progress report to the date of discharge.” It adds that the discharge note “shall include all treatment provided since the last progress report and indicate that the therapist reviewed the notes and agrees to the discharge.” And: “Clinicians should consider the discharge note the last opportunity to justify the medical necessity of the entire treatment episode in case the record is reviewed.”

Functional reporting: two lines in the same section

Section 220.3 B states: “NOTE: Functional reporting and its associated documentation requirements are no longer applicable for claims or medical records for dates of service on and after January 1, 2019.” The progress-report list in section 220.3 D still states: “Functional documentation is required as part of the progress report at the end of each progress reporting period.” Both lines are quoted as the manual reads on November 10, 2026; this site does not reconcile them.

What this page does not do

It gives no payment figures, therapy thresholds, or billing codes, and it does not decide any claim. CMS directs providers with questions to their Medicare Administrative Contractor. It is not legal, billing, tax, or compliance advice. Confirm current rules with the agency that publishes them, your employer, and your state board.