You may have recently heard about Medicare’s functional limitation reporting (FLR) code processing glitch—a glitch that has caused some rehab therapists to receive claim denials for cases where the discharge process was a bit out of the ordinary. To help you identify the discharge situations for which you should report—and those for which you should not—we’ve put together the following guide:
If a Patient Self-Discharges and Returns After 60 or More Days
If a patient unexpectedly stops attending therapy, Medicare automatically considers the patient discharged 60 days after the last date of service on record. Once a patient reaches automatic discharge, the functional limitation reporting for that case is complete. If the same patient then returns to therapy, you need not complete discharge FLR for the patient’s original primary functional limitation. Instead, perform a new initial examination and proceed with FLR as if you were treating a new patient.
If a Patient Self-Discharges and Returns Within 60 Days to Treat the Same Functional Limitation
If a patient unexpectedly stops attending therapy but returns within 60 days to continue treatment for the same functional limitation for which they previously sought treatment, you need not complete discharge FLR for the patient. Instead, simply resume treating—and documenting FLR for—the patient as if he or she had never left therapy.
If a Patient Self-Discharges and Returns Within 60 Days to Treat a Different Functional Limitation
According to the APTA, if a patient unexpectedly stops attending therapy but returns within 60 days seeking treatment for a different functional limitation, you must complete discharge FLR for the patient’s original functional limitation during his or her first visit back. If you use WebPT, you’ll still evaluate and document the patient’s new functional limitation during the initial evaluation. However, on that date of service we will only submit the discharge data for the patient’s original functional limitation; we’ll submit the data for the patient’s new primary functional limitation on the patient’s second visit back to therapy. The next time you’ll need to complete functional limitation reporting data will be on the patient’s next progress note (at least ten visits from the patient’s second date of service).
If a Patient is Receiving Treatment for Two Different Cases From Two Different Therapists in the Same Clinic
If a patient is receiving treatment for two different diagnoses—and two different limitations—from two different therapists within your clinic, both therapists must decide together which of the two functional limitations is the patient’s primary one. While both therapists will continue to treat the patient, the therapist who is treating the patient’s primary functional limitation will take ownership of that patient’s functional limitation reporting. The other therapist will discharge the patient’s other (not primary) functional limitation and thus will cease reporting FLR for the patient. Throughout the patient’s treatment, both therapists must collaborate to ensure that their respective therapy goals align with the patient’s primary functional limitation goal—despite the fact that one therapist isn’t reporting FLR.
If a patient is receiving treatment for two different diagnoses—but only one limitation—from two different therapists within your clinic, one therapist will report all three categories of G-codes (current, goal, and discharge) and corresponding severity modifiers at the initial evaluation. Then, that therapists will continue to treat as normal without reporting any functional limitation data. The other therapist will complete functional limitation reporting for the patient as normal.
Has Medicare denied your claims for discharge reporting? What happened? Were you able to reverse the denial? Share your story in the comments section below.