WebPT Blog - Compliance
-
1 CommentsJun 5, 2013| Brooke Andrus
If the rules of Advance Beneficiary Notices of Noncoverage (ABNs) make you a bit confused, you’re definitely not alone. In an effort to shed some light on the ins and outs of ABNs and to highlight some recent changes to ABN requirements, Medicare rolled out a new set of FAQs clarifying their use. Here’s some info to help bring you up to speed:What is an ABN?
An ABN is a form practitioners use to notify a Medicare patient that Medicare might not cover the therapy services he or she is about to receive.
What is the purpose of an ABN?
ABNs allow beneficiaries (your patients) to make informed decisions about whether they would like to accept therapy services despite the possibility of having to pay for those services out-of-pocket. A signed ABN form serves as proof that a patient knew prior to accepting such services that he or she might have to pay out-of-pocket for them.
When should a therapist issue an ABN?
A therapist must issue an ABN in either of the following instances:
- Before providing items or services that the therapist believes or knows Medicare may not cover
- Before providing items or services that Medicare usually covers but may not consider medically reasonable and medically necessary for this particular patient in this particular case
In neither instance can a therapist issue an ABN after the fact (i.e., after Medicare denies a claim); therapists always must complete the form and have patients sign it prior to the time of service.
-
May 30, 2013| Heidi Jannenga PT
Thank you, Chuck, for presenting such detailed information on the Multiple Procedure Payment Reduction (MPPR) changes. My biggest takeaway from Chuck’s post is that, now more than ever, clinic owners must focus on practice management and truly pay attention to their business. Understanding the metrics of your practice is crucial in this age of declining reimbursements and frequent regulatory changes. There are three crucial metrics that I think come into play when assessing MPPR’s impact on your clinic:1. Clinic cost per visit: This is your cost of doing business. What does it cost you per patient visit to run your clinic (with all expenses divided by the number of patients you see per day)? If you then add in whatever profit margin you would like your practice to make, your total will equal the minimum revenue per patient visit that your practice can sustain. If you accept insurance payments that are less than this amount, you will essentially lose money on each visit or cut into your profit margin.
2. Net revenue per visit: This is the average dollar amount per patient visit that you receive in reimbursement from each insurance. The clinic average is the average dollar amount per patient visit that you receive across all of your insurances. Make sure that your net revenue per visit for each insurance that you accept is above the clinic cost per visit. Essentially, you want to bring in more money than you spend. Consider your average Medicare visit reimbursement with MPPR: is it higher than your cost per visit? If not, then you’ll need to make adjustments to bring your cost per visit down. If yes, then MPPR may have only minimal impact on your overall business (pending the next factor).
-
May 23, 2013| Erica Cohen
We all know that functional limitation reporting (FLR) means (a little) more work for (basically) the same reward. And that can be a hard pill to swallow for many therapists who are already stretched thin as a result of increasing caseloads and increasingly stringent documentation requirements. Even so, taking the easy road—the low road—and gaming the system—and thus, this profession—is not the answer. It never is. This—just like everything else you do for your patients, your practice, and your profession—is a matter of pride. So make your reporting something to be proud of—it’s a testament to who you are as an individual and as a therapist.Over the last several months, we’ve come across more than a few concerning questions from the community regarding ways to get around functional limitation reporting. Today, we thought we’d address two of them: crosswalking scores from objective measurement tools to severity modifiers and misrepresenting patient progress.
Crosswalking Scores
To satisfy functional limitation reporting requirements, therapists must assign a severity modifier to their patient’s current (or discharge) status G-code as well as their projected goal status G-code. These severity modifiers communicate where a patient is currently in terms of functional limitation and where he or she should be after treatment (i.e., long term functional goal).
-
May 22, 2013| Charlotte Bohnett
Today's blog post comes from WebPT Senior Writer Charlotte Bohnett, contributing writer Erica Cohen, and WebPT Co-Founder Heidi Jannenga, PT.
Monday and Tuesday we hosted webinars on functional limitation reporting. We got tons of great questions. Here are the most frequently asked ones:
The Basics
What is functional limitation reporting?
Beginning July 1, 2013, CMS is requiring that you complete functional limitation reporting (FLR) on all Medicare part B patients in order to receive reimbursement for your services. Essentially, FLR is a type of reporting focused on the progress of the patient through measurable goals, and supporting documentation is required for reimbursement.
Who created FLR?
CMS developed functional limitation reporting as part of the Middle Class Tax Relief Act of 2012, which mandated the collection of the following information regarding the beneficiaries on the claim form: function and condition, therapy services furnished, and outcomes achieved on patient function. CMS is enforcing noncompliance.
Why functional limitation reporting?
CMS created FLR to collect information regarding beneficiaries’ functions and conditions, the services therapists provide, and the functional outcomes patients achieve. CMS will use all of this information to better understand the beneficiary population that uses therapy services and how their functional limitations change as a result of the therapy they complete. Furthermore, CMS will use the data they collect to reform future payment structures.
Does FLR apply to rehab therapists?
According to the APTA, “All practice settings that provide outpatient therapy services must perform FLR. Specifically, FLR applies to physical therapy, occupational therapy, and speech-language-pathology (SLP) services furnished in hospitals, critical access hospitals, skilled nursing facilities, comprehensive outpatient rehabilitation facilities (CORFs), rehabilitation agencies, home health agencies (when the beneficiary is not under a home health plan of care), and in private offices of therapists, physicians, and nonphysician practitioners.”How does FLR work?
Therapists will report functional limitations (current status and projected goal for initial examination and at minimum every tenth visit or progress note, and then discharge status and projected goal at discharge) using G-codes and corresponding severity modifiers for all eligible Medicare patients.What are G-codes and severity modifiers?
G-codes are quality data codes therapists will use to describe their patients’ functional limitation—that is, the primary reason they’re seeking therapeutic services. Upon identifying the primary functional limitation, the therapist will select the corresponding G-code and then assign a severity modifier, which indicates the extent of the severity of the functional limitation. Therapists select an appropriate severity modifier based on the score of an outcome measurement tool as well as their skilled clinical knowledge. Lastly, therapists must also include a therapy modifier (GO, GP, and GN) to indicate that they’re providing therapy services under an OT, PT, or SLP plan of care, respectively.For a full list of the FLR G-codes and a severity modifier chart, check out this blog post.
What are the benefits of FLR?
With FLR, rehab therapists finally have an outlet to prove that what they do clinically is relevant and deserves payment. It’s an opportunity for rehab therapy professionals to demonstrate the value of their profession. FLR also allows rehab therapists to incorporate clinical judgement to truly assess the severity of a patient’s functional limitation without relying on patients’ faulty self-assessments, and that leads to better, more effective treatment.
-
May 13, 2013| Erica Cohen
If you’ve been paying attention to our blog posts, our webinars, and functionallimitation.org for the past few weeks, you might think we here at WebPT have gone a little FLR-crazy. And you’d be right. You see, the latest CMS regulation—functional limitation reporting (FLR)—has some pretty severe consequences for noncompliance. Namely, if you don’t comply, you don’t get paid. I don’t know about you, but that seems like an awful lot of pressure. So, we’ve set out to give you all the information and tools you need (including a fully integrated functional limitation reporting solution available within WebPT after May 17) to become an FLR Master. This way, in addition to supreme bragging rights as a result of your mastery, you’ll also get paid. We think that’s kind of a big deal.
With that in mind, here’s a flowchart that walks you through FLR in theory. Essentially, this is everything you’ll need to consider if you’re doing FLR on your own. Holy steps, Batman!
Following this chart is a nifty FLR in WebPT SmartArt graphic. Notice the difference? You don’t have have to be an FLR Master to see that WebPT’s integrated functional limitation reporting solution (coming May 17) is going to make FLR easy peasy.
-
May 9, 2013| Erica Cohen
With July 1 right around the corner, we know what’s on your mind: functional limitation reporting (FLR). That’s why we’ve dedicated (almost) this entire month to the ins and outs of G-codes and severity modifiers. But perhaps our discussions have been a little too theoretical for your liking. (We know FLR is one spicy meatball.) If that’s the case, don’t fret. Here’s a more concrete patient example to help solidify your understanding of CMS’s latest regulation. First, some handy dandy references for said example.References
G-Codes:
Mobility: Walking & Moving Around
- G8978 Mobility: walking and moving around functional limitation, current status, at therapy episode outset, and at reporting intervals.
- G8979 Mobility: walking and moving around functional limitation, projected goal status, at therapy episode outset, at reporting intervals, and at discharge or to end reporting.
- G8980 Mobility: walking and moving around functional limitation, discharge status at discharge from therapy or to end reporting.
-
May 7, 2013| Heidi Jannenga PT
There’s no denying that functional limitation reporting is a little more work to get the same (or less if you consider MPPR) reimbursement and that ignites fear among some in our industry. But you shouldn’t be fearful; you should be frustrated at our own inability to document to a standard that shows our clinical relevance and the amazing outcomes we achieve every day in clinics across the US. We haven’t effectively demonstrated evidence-based practice yet, nor have we properly articulated progress through functional gain. Medicare has been warning us that something like this was coming, and we never ponied up. Now, we have functional limitation reporting (FLR).I believe we’re moving toward a pay-for-performance structure. FLR is the initial facilitation of that with Medicare patients, and it’s only a matter of time before other carriers follow suit. Essentially, resistance is futile. But why resist? That’s my point in this month’s founder letter: do not resist; do not be afraid; and do not let frustration get the best of you. Because FLR is actually good. How? This reporting affords us the opportunity to demonstrate our expertise and relevancy—and get paid for it. You are essentially already completing these things every day in your clinical practice—now you just have to document it. So get fired up. We need to prove ourselves, and prove ourselves we will. Let’s tell Medicare to bring it on!
With that said, FLR is not about crosswalking a score for an objective measure to a category of severity—in fact, doing so would defeat the purpose of FLR. In reality, FLR is about using your clinical expertise to determine limitation and severity. It’s about your clinical judgment. How many times do you give a patient a self-evaluative outcome measurement tool to complete and the results leave you wondering how he or she came to those conclusions? It’s clear that the patient has an entirely false sense of self, and you know it. FLR requires that you incorporate your clinical judgment to truly assess the severity of a patient’s functional limitation as well as his or her progress. Ultimately, you shouldn't rely solely on a patient’s’ potentially faulty self-assessment as you develop your plan of care. Instead, you should apply your expertise to provide better, more objective treatment.
I cannot stress it enough: you’re proving your worth and getting paid for it. So, stop getting bogged down on modifiers, codes, and progress notes. Really, once you “get it,” FLR becomes second nature in your documentation workflow. (Plus, this month WebPT will launch a fully-integrated FLR feature, so it’ll be super streamlined.) You’re simply telling the story in a way that validates your services.
With FLR, we finally have an outlet to prove that what we do clinically is relevant and deserves payment. We should all view these new requirements as an opportunity for us to finally demonstrate the value of our profession. We’re badasses; we know this. Now let’s show it.
-
May 2, 2013| Charlotte Bohnett
Beginning July 1, 2013, CMS is requiring that you complete functional limitation reporting (FLR) on Medicare part B patients in order to receive reimbursement for your services. While WebPT can monumentally help with this task through our soon-to-be-released integrated functional limitation reporting feature, it’s important that you still understand FLR thoroughly, especially because clinical judgment does play a large role in its completion. So, with that in mind, let’s tackle the basics of FLR.Why functional limitation reporting?
CMS created FLR to collect information regarding beneficiaries’ functions and conditions, the services therapists provide, and the functional outcomes patients achieve. CMS will use all of this information to better understand the beneficiary population that uses therapy services and how their functional limitations change as a result of the therapy they complete. Furthermore, CMS will use the data they collect to reform future payment structures.Does FLR apply to rehab therapists?
According to the APTA, “All practice settings that provide outpatient therapy services must perform FLR. Specifically, FLR applies to physical therapy, occupational therapy, and speech-language-pathology (SLP) services furnished in hospitals, critical access hospitals, skilled nursing facilities, comprehensive outpatient rehabilitation facilities (CORFs), rehabilitation agencies, home health agencies (when the beneficiary is not under a home health plan of care), and in private offices of therapists, physicians, and non-physician practitioners.” -
Mar 25, 2013| Heidi Jannenga PT
Today's blog post comes from WebPT Co-Founder Heidi Jannenga, PT, MPT, ATC/L.
Today, copays are the norm, and they’re only becoming more costly. To top it off, many insurance plans—especially those that individuals and small businesses purchase (including HSAs)—have very large deductibles that patients must meet before insurance will pay for anything. While it’s obvious that these increased copays and deductibles put a burden on patients, they also burden physical therapy practices. How? Many practices don’t have the procedures in place for effective fee collection from patients—especially not in person. Instead, many are willing to simply write off cash collections when the patient doesn’t pay. But with declining insurance reimbursements, successful over-the-counter collections are more important than everWhat are the implications of not collecting?
In an APTA Podcast, Nancy White says, “studies show that the chance of collecting from a patient drops almost 20% as soon as the patient leaves the office.” Anecdotally, I think its higher—especially after patient discharge. While some front offices may find it easier to simply mail a statement after the visit, there are usually hidden costs associated with this. In fact, according to Nancy White, there is data that indicates “it may cost between $5–$10 per patient to send and process each statement by mail.” Not to mention that when you mail statements rather than collect upfront, you’re decreasing your chances of receiving payment and there’s a self-made waiting period for any payments patients do send. -
Mar 11, 2013| Erica Cohen
Today's blogs post comes from WebPT Co-Founder and PT Heidi Jannenga, Marketing Manager Mike Manheimer, and Senior Writers Erica Cohen and Charlotte Bohnett.
Last month’s webinar on Medicare was our most highly attended webinar to date. And that’s really not surprising, because wherever Medicare goes, questions follow. But unfortunately, we couldn’t get to them all live. So we thought we’d put together a blog post will all the great questions you asked and our answers. That way, you can access it wherever, whenever you want. Ready to jump in? Here’s your Medicare Q&A.
(P.S. Are you a first timer to thiswebinar or looking for a refresher? Click here to rewatch the webinar.)
