How to Complete Functional Limitation Reporting with Multiple Plans of Care

Written by Erica Cohen on February 12, 2014

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. Hopefully by now you know how this works (if not, check out this blog post), and it should be relatively simple?in theory, at least. But in practical application, there have been more than a few puzzling one-off situations. Today, let’s talk specifically about functional limitation reporting with multiple plans of care based on this APTA podcast. (Click here if you missed last week’s post on completing functional limitation reporting with multiple diagnoses under a single plan of care.)

Two Plans of Care in Different Disciplines within the Same Practice

According to the APTA, in this situation (an example of which might be a stroke patient receiving treatment from a physical and occupational therapist in the same practice), each therapist should “identify and report the patient’s primary functional limitation under his or her respective plan of care, and report accordingly.”

Two Plans of Care in The Same Disciplines within the Same Practice

According to the APTA, reporting guidance for this type of situation is complicated because Medicare tracks functional limitation reporting data per beneficiary, per therapy discipline, and per billing provider (NPI). So in this scenario:

  • The first therapist identifies the patient’s primary functional limitation and reports it under the first plan of care.

  • The second therapist completes functional limitation reporting (using all three G-codes) as if he or she were performing a one-time visit on the date of evaluation or re-evaluation for the second plan of care.

Medicare will count the therapy dates of service for both plans of care cumulatively to determine reporting intervals for functional limitation reporting. The APTA notes, however, that “the date of service for which the [second therapist reports the] three G-codes for the second plan of care does not count toward the overall cumulative visit count”—and no one may submit any more G-codes in the same discipline on that date of service.

Additionally, the APTA recommends “that the non-reporting therapist continue to document progress throughout the episode with respect to the primary functional limitation under the second plan of care” and “resume reporting [if] the patient [is] discharged from the first plan of care.”

Podcast Example and Charts:

Patient X is a 65-year-old, right-handed female who slipped and fell about two weeks ago, fracturing her right shoulder.

  • On July 1, 2013, she has an initial evaluation, at which time, her physical therapist determines that her primary functional limitation is carrying, moving, and handling objects.

    • Patient X is 75% limited, and the therapy goal is to decrease her functional limitation to 15%.

    • The therapist reports G8984 with the CL modifier and G8985 with the CI modifier.

  • On the sixth visit, the patient presents with a new therapy referral from a different physician for urinary incontinence. Another physical therapist at the practice, who specializes in pelvic health, sees the patient for an evaluation.

    • The two therapists collaboratively determine that the patient’s primary limitation remains carrying, moving, and handling objects.

      • The pelvic health therapist reports three G-codes to reflect the limitation (self-care) associated with the second plan of care: G8987 with the CJ modifier, reflecting current functional limitation; G8988 with the CI modifier, reflecting the projected goal; and G8989 with the CJ modifier, reflecting the end reporting status.

  • The next reporting interval will be on or before the 11th visit (see chart #1 below).

According to the APTA, the three G-codes alert Medicare “that a second plan of care [began] on this date of service for the same therapy discipline at the same facility where there is ongoing reporting under another physical therapy plan of care. Reporting of the G-codes does not restart the visit count in this case, but all dates of service under both plans of care now will count in determining the next scheduled reporting interval—except the sixth visit, which will not count in the overall cumulative visit count.”

Chart #1

Date of Service 6/1 (1) 6/3 6/5 6/10 6/13 6/17 (6) 6/19 6/21 6/24 6/28 7/1 (11)
PT #1 Eval Visit Visit Visit Visit Visit Visit Visit
PT #2 Eval Visit Visit Visit
Reporting PT #1 G8984 CL G8985 CI PT #2 G8987 CJ G8988 CI G8989 CJ PT #1 G8984 CJ G8985 CI

If upon evaluation, the therapists had determined that Patient X’s primary functional limitation was self-care (associated with her urinary incontinence diagnosis), not carrying, moving, and handling objects, then:

  • On that sixth visit, the pelvic health therapist would have reported three G-codes to reflect the limitation (self-care) associated with the second plan of care: G8987 with the CJ modifier, reflecting current functional limitation; G8988 with the CI modifier, reflecting the projected goal; and G8989 with the CJ modifier, reflecting end reporting status.
  • On the next (seventh) visit, the first therapist would have ended reporting on the primary functional limitation of carrying, moving, and handling objects—G8986 with the CJ modifier and G8985 with the CI modifier.
  • On the next (eighth) visit, the pelvic health therapist would begin reporting on the subsequent functional limitation of self-care by reporting G8987 with the CJ modifier and G8988 with the CI modifier.
  • The next reporting interval would be on or before the 18th visit (see chart #2 below).
Date of Service 6/1 (1) 6/3 6/5 6/10 6/13 6/17 (6) 6/19 (7) 6/21 (8) 7/26 (18)
PT #1 Eval Visit Visit Visit Visit Visit Visit Visit
PT #2 Eval Visit Visit
Reporting PT #1 G8984 CL G8985 CI PT #2 G8987 CJ G8988 CI G8989 CJ PT #1 G8986 CJ G8985 CI PT #2 G8987 CJ G8988 CI PT #1 G8984 CH G8985 CI

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 advocacy@apta.org. If you’re not an APTA member, but you still have questions—or if you just feel like asking us instead—email functionallimitation@webpt.com.

Posted Under: Functional Limitation Reporting
About Erica Cohen

Erica Cohen is a writer and editor with experience in both the healthcare and technology industries. After graduating summa cum laude from Arizona State University, Erica obtained her Master of Arts from the University of Chicago in Social Science. She currently runs her own writing company in San Francisco, California. For questions about functional limitation, please email functionallimitation@webpt.com.