Is Your Clinic Prepared for Functional Limitation Reporting?

Beginning July 1, 2013, CMS is requiring that you complete functional limitation reporting (FLR) in order to receive reimbursement for your services.

So how is your clinic gearing up for this change? If you're a WebPT Member, we're making it easy. Take the FLR Quiz to test your knowledge or check out the webinar hosted by WebPT Co-Founder Heidi Jannenga, PT, MPT, ATC/L, to learn everything you need to know about the new reporting requirements as well as how to implement the new G-codes within WebPT.

Take the Quiz

Think you know functional limitation reporting? Prove it with this ten question quiz.

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Watch the Webinar

WebPT Co-Founder Heidi Jannenga shows you everything you need to know about FLR.

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Get the Guide

Need to study before the quiz? Get the Ultimate Guide to functional limitation reporting.

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Functional Limitation Reporting is Here! Ready to See It In Action?

From the Blog

Functional Limitation Reporting Glitches: Past and Present

Written by admin on March 25, 2014
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Today’s post comes from Tom Ambury, PT and compliance officer at PT Compliance Group

At the Beginning

On January 1, 2013, the Centers for Medicare and Medicaid Services (CMS) put functional limitation reporting requirements into effect—with a six month practice period—for PTs, OTs, and SLPs. As of July 1, 2013, all rehab

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PTA Involvement in Reporting Functional Limitation Data

Written by Brooke Andrus on September 10, 2013

The rules on functional limitation reporting (FLR) make it clear that clinical judgment is essential to the reporting process, and that means therapist participation is essential, too. In other words, a physical therapist must perform any FLR steps involving clinical assessment. You might think that takes physical therapy assistants (PTAs)

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Could FLR Use a Makeover? MedPac Sure Thinks So.

Written by Erica Cohen on August 1, 2013

By now, you know everything there is to know about functional limitation reporting (FLR)—almost. You know what to report, when to report it, and how to report it. You know what to do if you receive a claim rejection from Medicare. You even know the very best way to stay

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How to Handle Claims Rejected for Lacking FLR

Written by Brooke Andrus on July 30, 2013

The July 1 deadline for functional limitation reporting (FLR) compliance has come and gone, and for those who neglected to include G-codes and severity modifiers on their Medicare claims, the rejection letters are now rolling in. Does this sound like a page from your life story? If so,

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Frequently Asked Questions

What is functional limitation reporting?

Beginning July 1, 2013, CMS is requiring that you complete functional limitation reporting (FLR) on all Medicare part B patients in order to receive reimbursement for your services. Essentially, FLR is a type of reporting focused on the progress of the patient through measurable goals and supporting documentation is required for reimbursement.

Who created FLR?

CMS developed functional limitation reporting and they're enforcing noncompliance.

Why functional limitation reporting?

CMS created FLR to collect information regarding beneficiaries' functions and conditions, the services therapists provide, and the functional outcomes patients achieve. CMS will use all of this information to better understand the beneficiary population that uses therapy services and how their functional limitations change as a result of the therapy they complete. Furthermore, CMS will use the data they collect to reform future payment structures.

Does FLR apply to rehab therapists?

According to the APTA, "All practice settings that provide outpatient therapy services must perform FLR. Specifically, FLR applies to physical therapy, occupational therapy, and speech-language-pathology (SLP) services furnished in hospitals, critical access hospitals, skilled nursing facilities, comprehensive outpatient rehabilitation facilities (CORFs), rehabilitation agencies, home health agencies (when the beneficiary is not under a home health plan of care), and in private offices of therapists, physicians, and nonphysician practitioners."

How does FLR work?

Therapists will report functional limitations (current status and projected goal for initial examination and at minimum every tenth visit or progress note, and then discharge status and projected goal at discharge) using G-codes and corresponding severity modifiers for all eligible Medicare patients.

What are G-codes and severity modifiers?

G-codes are quality data codes therapists will use to describe their patients' functional limitation—that is, the primary reason they're seeking therapeutic services. Upon identifying the primary G-code, the therapist will select the corresponding G-code and then assign a severity modifier, which indicates the extent of the severity of the functional limitation. Therapists select an appropriate severity modifier based on the score of an outcome measurement tool as well as their skilled clinical knowledge. Lastly, therapists must also include a therapy modifier (GO, GP, and GN) to indicate that they're providing therapy services under an OT, PT, or SLP plan of care, respectively.

For a full list of the FLR G-codes and a severity modifier chart, check out this blog post.

What are the benefits of FLR?

With FLR, rehab therapists finally have an outlet to prove that what they do clinically is relevant and deserves payment. It's opportunity for rehab therapy professionals to demonstrate the value of their profession. FLR also allows rehab therapists to incorporate clinical judgment to truly assess the severity of a patient's functional limitation without relying on patients' faulty self-assessments, and that leads to better, more effective treatment.

When should my clinic be ready for FLR?

The sooner the better! But FLR becomes mandatory on July 1, 2013.

What changes do I need to make to my workflow to accommodate FLR?

First, you must complete functional limitation reporting for all Medicare patients you treat. You'll denote current status and projected goal for the initial examination and at minimum every tenth visit or progress note. Then, you'll note discharge status and projected goal at discharge. All of this you'll do using G-codes and corresponding severity modifiers.

Your documentation method will greatly influence how you will incorporate FLR into your workflow. Paper charting will prove the most cumbersome with FLR as you'll need to constantly reference a G-code list and severity modifier chart until you have it all memorized. You'll also have to revise your paper charts to accommodate this reporting.

If you document digitally, then it's crucial you have a conversation with your EMR vendor to ensure they're entirely prepared for FLR. Depending on how they have FLR set up within the system, you may need to adjust your workflow. WebPT, on the other hand, has fully integrated FLR into the entire SOAP Note, meaning therapists' documentation style and flow can remain the same. See it for yourself; schedule your free demo today.

How do I know if my clinic is compliant with FLR?

This also depends on how you document. If you chart on paper, then unfortunately, the only way you'll know if you're completing FLR accurately is if CMS reimburses you for your services—or doesn't.

If you document digitally, then your EMR should have alerts in place to ensure you're entirely compliant with your reporting. For example, WebPT won't let you advance in your SOAP Note or create new notes (i.e., initial exam, progress note, or discharge summary) without completing FLR requirements. Furthermore, with WebPT, it's not possible to finalize a note without completing FLR requirements.

Make sure you contact your EMR vendor to determine what measures they have in place to ensure FLR compliance. Interested in seeing WebPT's solution? Schedule a demo today.

What's the easiest or fastest way to become compliant with FLR?

The easiest and fastest way to become entirely compliant with FLR is to let WebPT do all the heavy lifting for you. We've already integrated FLR into our application to ensure that all of our Members are compliant by the time the mandated regulations go into effect.

Don't have WebPT yet? We can have your clinic up and running in one day. Schedule your free demo today.

How does WebPT handle FLR better or differently than competitors?

Our solution is unique in its integration within the existing documentation framework. While most other EMR systems make functional limitation reporting more of an accessory that appears at the end of a patient note, WebPT has built it right into the documentation. This approach creates a stronger connection between functional limitation reporting and actual patient progress, thus maximizing the opportunity therapists now have to prove their effectiveness in treating and healing patients.

Don't have WebPT yet? We can have your clinic up and running in one day. Schedule your free demo today.

Is this G-coding requirement applicable to home health PT/OT/ST?

According to the APTA, "All practice settings that provide outpatient therapy services must perform FLR. Specifically, FLR applies to physical therapy, occupational therapy, and speech-language-pathology (SLP) services furnished in hospitals, critical access hospitals, skilled nursing facilities, comprehensive outpatient rehabilitation facilities (CORFs), rehabilitation agencies, home health agencies (when the beneficiary is not under a home health plan of care), and in private offices of therapists, physicians, and non-physician practitioners."

Based on this quote, home health agencies must perform functional limitation reporting when the beneficiary is not under a home health plan of care.

Once a patient with multiple functional limitations reaches goal status on his or her primary functional limitation, how do I switch the patient to a new primary functional limitation? Can I do two progress notes in two successive visits?

If a new functional limitation exists once the patient reaches the goal of their initial functional limitation, you'll take the following steps:

  • Discharge initial primary limitation.
    • Within the Subjective Section, determine and select a new functional limitation category.
    • Within the Objective Section, select a new appropriate functional assessment tool(s) or objective measure(s).
    • Then, based on the functional assessment tool(s), determine the severity of this new limitation and select the corresponding modifier.
  • Determine the new projected long-term goal based on the current functional limitation status and other patient information.
  • Find the appropriate G-code and modifier on your billing sheet. If you have integrated billing, these will then pass through the integration to the appropriate billing software:
    • Current status with severity modifier
    • Projected goal with severity modifier

My clinic does not use a billing software that is compatible with WebPT, so we do the slow data-entry method. How should the actual claim appear to Medicare? Can you give me an example of what a HCFA 1500 will look like for billing a visit to Medicare?

In submitting claims, you'll report FLR G-codes as a separate line item. Basically, you'll have your regular CPT codes indicating what you've done for the treatment, and then you'll list your G-codes as part your non-payable codes ($0.00 Private or $0.01 Institutional). Functional limitation data is comprised of three pieces of info: G-Code, Severity Modifier, and Therapy Modifier. For multiple page claims, complete total for item 27 on the last CMS-1500 claim form.

To see an example or hear Heidi explain this all further, please watch our Functional Limitation Reporting Webinar here: http://www.functionallimitation.org/webinar

If a patient does not continue therapy, and I did not know in advance that his or her most recent visit would be the last, how should I complete the discharge note?

You would complete a quick discharge. This note would not contain the discharge G-code and severity modifier because you're not generating a claim for the visit. You would then explain in the notes about the patient not continuing therapy. CMS would not assess a penalty for missing information because there would be no claim for the visit.

How does one use an outcome measurement tool to find a percentage score and select the proper severity modifier? Many functional tests don't directly produce a percentage that corresponds to severity modifiers.

Clinical judgment must always play a role in functional limitation reporting. Upon selecting a patient's primary functional limitation, a therapist must select a corresponding modifier based on the combination of an outcome measurement tool and clinical judgment. In short, it's not about crosswalking a score for an objective measure to a category of severity. It's about demonstrating clinical expertise.

What should I do if a patient achieves the original goal of his or her primary functional limitation, but there is still potential for additional improvement? Should I set a new goal or would it be necessary to "discharge" the first goal?

If, during a certain episode of care, you determine that a patient's projected goal is either too high or too low, you would simply change the goal status on the next progress note and document why in the note.

What is CMS? Do most insurances require functional limitation reporting?

CMS is the Center for Medicaid and Medicare Services. Clinics will only need to comply with functional limitation reporting if they see Medicare patients. If your clinic doesn't see Medicare patients, you won't need to worry about functional limitation reporting at this time.

Where can I find a list of the G-codes and the severity/complexity modifier chart you have in the slide show?

Feel free to download the slides at the top of this page. If you are an APTA member, you can also get more info here: http://www.apta.org/payment/medicare/codingbilling/functionallimitation/

Does the corresponding modifier need to be in the documentation or just on the claim forms?

You must document the G-codes and modifiers in your notes and on your claim forms by July 1, 2013.

My understanding is that I must choose two (2) outcome measurements (that do not change) to report on for 2013 with 50% of my Medicare patients. The G-code system sounds like you choose an outcome measurement test based on each specific PT. Please clarify this for my PQRS reporting.

PQRS and functional limitation reporting requirements are completely separate Medicare requirements for 2013. For PQRS, you must select three measures to report on for at least 50% of your Medicare patients if you are using the claims-based reporting method. For functional limitation reporting, CMS is not requiring a specific number of outcome tools you need to use to assess the functional limitation of your patients; that is up to you, as the PT. However, you must use functional limitation scoring as part of your assessment in determining your patient's severity impairment percentage and then report that to CMS (in the form of a G-code and a corresponding severity modifier).

We are a pediatric outpatient clinic. I keep hearing about functional limitation reporting and PQRS. I don't think this applies to us but want to be sure. We bill Medicaid but not Medicare. Can you let me know if this is something we need to be concerned with?

You are correct. Currently, functional limitation reporting and PQRS are for Medicare patients only. If you do not see Medicare patients, you do not have any obligations to complete PQRS or functional limitation reporting at this time.

Do you have a webinar on the PQRS medicare issue? I liked the functional limitation webinar.

Have a question about FLR? Don't see your answer here?

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G-Codes and Severity Modifiers for Functional Limitation Reporting

You've got a handle on functional limitation reporting (FLR). You understand the how, the who, the why, and the when. All you need now are the actual G-codes and severity modifiers that you will use to complete the required reporting. To help you out, we compiled a comprehensive list of codes organized by category. Six of the categories apply to physical and occupational therapy, while the other eight apply to speech-language pathology.

Remember, G-codes and accompanying modifiers must appear on claims in pairs. To receive reimbursement for their services, therapists must report these codes at the initial examination, at minimum every tenth visit (or progress note), and at discharge.

Listed below are the 42 new G-codes you'll use to denote primary functional limitations, followed by a table containing the seven FLR severity modifier codes.

Physical Therapy and Occupational Therapy G-Codes

Mobility: Walking & Moving Around

G Code Description Short Descriptor
G8978 Mobility walking and moving around functional limitation, current status, at therapy episode outset, and at reporting intervals Mobility current status
G8979 Mobility walking and moving around functional limitation, projected goal status, at therapy episode outset, at reporting intervals, and at discharge or to end reporting Mobility goal status
G8980 Mobility walking and moving around functional limitation, discharge status, at discharge from therapy or to end reporting Mobility discharge status

Changing & Maintaining Body Position

G Code Description Short Descriptor
G8981 Changing and maintaining body position functional limitation, current status, at therapy episode outset, and at reporting intervals Body pos current status
G8982 Changing and maintaining body position functional limitation, projected goal status at therapy episode outset, at reporting intervals, and at discharge or to end reporting Body pos goal status
G8983 Changing and maintaining body position functional limitation, discharge status, at discharge from therapy or to end reporting Body pos discharge status

Carrying, Moving & Handling Objects

G Code Description Short Descriptor
G8984 Carrying, moving, and handling objects functional limitation, current status, at therapy episode, and at reporting intervals Carry current status
G8985 Carrying, moving, and handling objects functional limitation, projected goal status, at therapy episode outset, at reporting intervals, and at discharge or to end reporting Carry goal status
G8986 Carrying, moving, and handling objects functional limitation, discharge status, at discharge from therapy or to end reporting Carry discharge status

Self Care

G Code Description Short Descriptor
G8987 Self care functional limitation, current status, at therapy episode outset, and at reporting intervals. Self care current status
G8988 Self care functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting Self care goal status
G8989 Self care functional limitation, discharge status, at discharge from therapy or to end reporting Self care discharge status

Other PT/OT Primary Functional Limitation

G Code Description Short Descriptor
G8990 Other physical or occupational primary functional limitation, current status, at therapy episode outset, and at reporting intervals Other PT/OT current status
G8991 Other physical or occupational primary functional limitation, projected goal status, at therapy episode outset, at reporting intervals, and at discharge or to end reporting Other PT/OT goal status
G8992 Other physical or occupational primary functional limitation, discharge status, at discharge from therapy to end reporting Other PT/OT discharge status

Other PT/OT Subsequent Functional Limitation

G Code Description Short Descriptor
G8993 Other physical or occupation subsequent functional limitation, current status, at therapy episode outset, and at reporting intervals Sub PT/OT current status
G8994 Other physical or occupational subsequent functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting Sub PT/OT goal status
G8995 Other physical or occupational subsequent functional limitation, discharge status, at discharge from therapy or to end reporting Sub PT/OT discharge status

Speech-Language Pathology G-Codes

Swallowing

G Code Description Short Descriptor
G8996 Swallowing functional limitation, current status, at therapy episode outset, and at reporting intervals Swallow current status
G8997 Swallowing functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting Swallow goal status
G8998 Swallowing functional limitation, discharge status, at discharge from therapy or to end reporting Swallow discharge status

Motor Speech

G Code Description Short Descriptor
G8999 Motor speech functional limitation, current status, at therapy episode outset, and at reporting intervals Motor speech current status
G9186 Motor speech functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting Motor speech goal status
G9158 Motor speech functional limitation, discharge status, at discharge from therapy or to end reporting Motor speech discharge status

Spoken Language Comprehension

G Code Description Short Descriptor
G9159 Spoken language comprehension functional limitation, current status, at therapy episode outset, and at reporting intervals Spoken language comprehension current status
G9160 Spoken language comprehension functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting Spoken language comprehension goal status
G9161 Spoken language comprehension functional limitation, discharge status, at discharge from therapy or to end reporting Spoken language comprehension discharge status

Spoken Language Expression

G Code Description Short Descriptor
G9162 Spoken language expression functional limitation, current status, at therapy episode outset, and at reporting intervals Spoken language expression current status
G9163 Spoken language expression functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting Spoken language expression goal status
G9164 Spoken language expression functional limitation, discharge status, at discharge from therapy or to end reporting Spoken language expression discharge status

Attention

G Code Description Short Descriptor
G9165 Attention functional limitation, current status, at therapy episode outset, and at reporting intervals Attention current status
G9166 Attention functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting Attention goal status
G9167 Attention functional limitation, discharge status, at discharge from therapy or to end reporting Attention discharge status

Memory

G Code Description Short Descriptor
G9168 Memory functional limitation, current status, at therapy episode outset, and at reporting intervals Memory current status
G9169 Memory functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting Memory goal status
G9170 Memory functional limitation, discharge status, at discharge from therapy or to end reporting Memory discharge status

Voice

G Code Description Short Descriptor
G9171 Voice functional limitation, current status, at therapy episode outset, and at reporting intervals Voice current status
G9172 Voice functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting Voice goal status
G9173 Voice functional limitation, discharge status, at discharge from therapy or to end reporting Voice discharge status

Other Speech Language Pathology

G Code Description Short Descriptor
G9174 Other speech language pathology functional limitation, current status, at therapy episode outset, and at reporting intervals Other speech language pathology current status
G9175 Other speech language pathology functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting Other speech language pathology goal status
G9176 Other speech language pathology functional limitation, discharge status, at discharge from therapy or to end reporting Other speech language pathology discharge status

Functional Limitation Severity Modifier Codes

Modifier Impairment Limitation Restriction
CH 0% impaired, limited, or restricted
CI At least 1% but less than 20% impaired, limited, or restricted
CJ At least 20% but less than 40% impaired, limited, or restricted
CK At least 40% but less than 60% impaired, limited, or restricted
CL At least 60% but less than 80% impaired, limited, or restricted
CM At least 80% but less than 100% impaired, limited, or restricted
CN 100% impaired, limited, or restricted

Want an FLR easy button? If you're a WebPT Member, you've got one. On May 17, WebPT is rolling out a fully integrated functional limitation reporting solution. Register here for our WebPT + FLR webinar on May 20 to see how easy it is to complete FLR within your WebPT documentation. Not yet a Member? Schedule your no-hassle demo today to learn more.

Check out these additional resources for more FLR info

Gawenda Seminars


Click here to go to Gawenda Seminars

PT Compliance Group


Click here to go to PT Compliance Group

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