If you’re reading this post, you’re probably new to functional limitation reporting (FLR), so let me take a moment to get you up to speed. According to an MLN Matters release from CMS, “Functional Reporting applies to all claims for therapy services furnished under the Medicare Part B outpatient therapy benefit and to Physical Therapy (PT), Occupational Therapy (OT), and Speech Language Pathology (SLP) services furnished under the Comprehensive Outpatient Rehabilitation Facility (CORF) benefit.” So, if you’re a PT, OT, or SLP, and you provide outpatient therapy services under Medicare Part B, FLR applies to you. And guess what? It’s mandatory—meaning you won’t get paid for eligible claims that don’t include FLR data.
You also should know that CMS requires you to perform functional limitation reporting on all Medicare Part B patients at the initial examination, at each progress note (or once every ten treatment days), at the time you submit an evaluative or re-evaluative procedure code, and at discharge. Happily, unlike the new gigantic ICD-10 code set, the FLR code set is relatively small. In fact, you have only 42 G-codes to choose from when completing FLR.
Wait, aren’t G-codes just a PQRS thing? Great question.
The answer: Nope.
There’s Something about G-Codes
While you’re right that PQRS does involve G-codes, you might not have realized that FLR’s got ’em, too. To be clear, FLR G-codes are not the same as PQRS G-codes—at all. They sound like twins, but there’s no relation whatsoever—not even fifth cousins, twice removed. They’ve never even met (unless you count that time they walked past each other at a Medicare conference last year).
But that doesn’t make it any easier to tell them apart at first glance, so let’s dig deeper into FLR G-codes (that’s why we’re here, after all). Here’s the deal: FLR G-codes are part of a “claims-based data collection strategy for outpatient therapy services” that’s required by the Middle Class Tax Relief and Jobs Creation Act of 2012. These G-codes are quality data codes designed to provide more information on “patient function during the therapy episode of care “ so CMS can better “understand beneficiary functional limitations and outcomes.” Basically, CMS needs to know more about who is receiving therapy and wants to make sure the therapy treatments Medicare patients receive are actually effective. (We know they are, but now we have to prove it by using G-codes.)
Three’s a Crowd
Here’s where it gets a little more confusing: G-codes don’t work alone. Once you’ve determined a patient’s primary limitation and assigned the appropriate G-code, you’ll need to identify a corresponding severity modifier to indicate the patient’s percentage of functional impairment according to a seven-point scale. You’ll determine your modifier selection based on the score of an outcome measurement tool (and your own professional opinion, of course).
Oh, and don’t forget about the therapy modifiers; CMS also requires one of these to specify whether the plan of care is from a PT, OT, or SLP.
Well, them’s the basics of FLR G-codes. Looking for a complete list of the 42 FLR G-codes? Check out this blog post. And for more information on FLR itself—including an explanation on the differences between FLR and PQRS G-codes—take a gander at our complete guide to G-codes.