This summer, CMS made functional limitation reporting (FLR) mandatory for all therapists who bill for outpatient services under Medicare Part B and wish to receive reimbursement. By now—hopefully—you know how this works: Whenever you conduct an initial evaluation (or reevaluation if medically necessary), complete a progress note (at minimum every ten visits), or discharge a patient, you must identify (or verify) the patient’s primary functional limitation, perform an outcome measurement test, and use that information in conjunction with your clinical expertise to determine the severity of the patient’s current limitation and set a treatment goal. After documenting this information in your notes, you must also submit it on your claim in the form of G-codes and corresponding severity modifiers. (For a refresher on FLR basics, check out this blog post.)
Sounds relatively simple, right? In theory, maybe. But in practical application, there have been more than a few one-off situations that have caused concern. Today, let’s talk specifically about functional limitation reporting at discharge based on this APTA podcast.
What if my patient stops therapy unexpectedly?
In the podcast, Heather Smith, program director of quality in the APTA’s Health Finance and Quality Department, said that CMS requires therapists to report functional limitation data (the projected goal and discharge status G-code with the corresponding severity modifier) to end reporting at discharge “when there is a formal discharge visit.” She goes on to say: “Based on Medicare guidance, if a patient unexpectedly self-discharges or discontinues therapy for any reason, the therapist is not required to submit data. In the case of an unplanned discharge, the therapist does not see the patient for the final visit and does not submit a final claim form. Therefore, the therapist cannot submit functional limitation data on the patient.”
What if my patient discharges from therapy during an unexpected visit?
According to the Medicare benefit policy manual, a clinician must complete a discharge note or summary that covers “the reporting period from the last progress report to the date of discharge.” If a patient discharges at an unexpected point during therapy, Smith says that “the clinician may base any judgments required to write the report on the treatment notes and verbal reports of the assistant or [other] qualified personnel.” Even in such a case, CMS strongly encourages therapists to document the appropriate G-codes and severity modifiers.
What if my patient stops therapy unexpectedly and then returns?
Recently, Medicare announced that it will “automatically discharge a therapy reporting episode” 60 calendar days after a patient’s last visit. If the patient stops therapy without notice and returns within 60 days to receive treatment for the same functional limitation, “the clinician must resume reporting following the functional limitation reporting requirements.”
What if my patient reaches his or her primary functional limitation goal but needs to continue therapy to address another limitation?
To proceed, the clinician must first discharge the patient’s original primary limitation and then, at the next date of service, begin reporting on the new primary functional limitation. According to Smith, “Therapists in this case can reference and report the G-codes included in the discharge note for the previous episode of care.”
For more FLR resources, check out the APTA’s FLR page. If you’re an APTA member and you have a question about FLR, you can contact the association directly at 800-999-2782, ext 8511, or at firstname.lastname@example.org. If you’re not an APTA member, but you still have questions—or if you just feel like asking us instead—email email@example.com.