Maybe not much!
Depending on the toe, pehaps not much for rehab.
If it is a 5th toe you would ususally not do much. If it is a great toe or a middle toe, maybe! this would depend on what the therapy was for. Is it postoperative after wires or plates or screws? Usually a broken toe is splinted and when healed, you are done. There may be instances where restoration of motion would be more important & need pt.