Gaming the System and Other FLR No-NosWe 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).


To determine which severity modifier is appropriate, therapists must use a combination of an evidence-based outcome measurement tool (OMT) as well as their clinical judgment. Crosswalking the score directly from the OMT to the severity modifier without taking into consideration additional clinical factors leaves out a very large piece of the patient’s diagnosis and treatment puzzle—context. And that comes from the clinical and highly skilled judgment of the therapist. Taking professional opinion out of the equation is telling the world that therapists aren’t all that necessary—and that a simple computer algorithm can do the same job. And we all know that’s not the case. You’re the professional—the expert. Your opinion matters—as does the patient’s story.

Misrepresenting Patient Progress

The purpose of functional limitation reporting requirements—at this point—is for Medicare to collect data on their beneficiaries’ collective progress in therapy and standard treatment practices in therapy clinics. No one is expecting every patient on every visit to achieve earth-shattering progress. Therapy doesn’t work that way. And by providing Medicare with false, inflated information on your patient’s progress, you may actually skew their understanding of realistic therapy expectations and goals. That’s not what anyone wants—that’s certainly not going to benefit our industry or our patients. So be honest. It’s completely reasonable for you to not change the severity modifier on every patient’s progress note—not because you didn’t evaluate them, but because perhaps their progress remained in the 20 percentage points between the low and high range of that modifier. And you know what? Eighteen percent progress is still pretty darn great in a lot of patients. And if you didn’t meet your goal—or something changes mid-treatment that leads you to reassess what’s realistic for your patient—that’s okay, too. Just make sure you’re documenting clearly the reasons why you’re making the decisions you are both in treatment plan development and in goal selection.

As Heidi pointed out in this month’s WebPT founder letter, FLR actually represents a real opportunity for therapists to improve their standing in the eyes of the medical industry—an opportunity not to be taken lightly or gamed.

“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.”

With this in mind, let’s all get a little fired up. Not about how to get out of FLR but about doing it right.