As of July 1, 2013, Medicare requires that all rehab therapy providers billing under Medicare Part B submit functional limitation data for each beneficiary in the form of G-codes and corresponding severity modifiers. Otherwise, Medicare will not reimburse you for your services.
Observation patients in the acute care setting are not exempt from this regulation. That could present a challenge for rehab therapists in some cases, as the status of such patients can quickly change from observation to admission. Also, many outcome measurement tools are not well suited to the acute care setting.
Still, a regulation is a regulation, and you can’t just ignore functional limitation reporting (FLR) simply because it’s inconvenient. To help you out, the APTA compiled a list of tests and measures—such as the six-minute walk test, timed up and go, and Activity Measure for Post-Acute Care (AM-PAC)—that therapists can perform in acute care settings to satisfy FLR requirements. (Click here to see the list.)
According to the APTA, therapists treating patients in acute care settings should only submit G-codes once per discipline for each date of service—even if a patient undergoes therapy treatment more than once a day. If a patient switches from outpatient to inpatient status, therapists can discontinue FLR, as inpatient treatment generally falls under Medicare Part A.
In the event of an unexpected discharge from observation status, therapists would not submit discharge data for FLR purposes. However, the APTA suggests that therapists still document G-codes for all discharges—including those that are unanticipated—even if the therapist does not submit the data to Medicare.
Additionally, in the event that Medicare denies a claim for an acute care stay under Part A and the facility rebills under Part B, the new claim will need to include FLR data. So, if you suspect that a patient’s Part A claim might eventually be resubmitted under Part B, you should document the appropriate G-codes and severity modifiers.
Remember, when it comes to FLR, it’s better to be safe than sorry. You can’t go back in time to determine a patient’s functional status, and if you do end up billing under Medicare Part B, you’ll need to include FLR data in order to receive reimbursement.