Last month, WebPT hosted another fantastic functional limitation reporting (FLR) webinar. If you missed it or simply want a refresher, this post is for you. Here were the most frequently asked questions and answers:
Q: How do I handle functional limitation reporting after July 1 for a current patient with no FLR data on record?
A: If you haven't submitted functional limitation reporting data on a patient prior to July 1, you should submit it (current and goal status G-codes plus severity and therapy modifiers) on the first claim with a date of service after July 1. WebPT strongly encourages you to begin functional limitation reporting on all qualifying visits immediately to ensure you continue to get paid following July 1.
Q: What G-code category does pelvic pain or incontinence fall within? How about pain or wound care?
A: Often, a patient seeking your services for wound care or pain of any sort also experiences a specific functional limitation as a result. For example, if the wound is on the leg, the patient may have limited mobility (Mobility: Walking and Moving Around). Or the pain could impair a patient’s ability to dress, bathe, or perform other activities necessary to caring for himself or herself (Self Care). Incontinence also falls within Self Care.
If this is not the case, and the patient is presenting with no functional limitation that falls within the predefined categories, you may use the “Other” category. Either way, be sure to clearly document the justification of your selection within your notes.
Q. Do I have to report FLR for patients with Medicare as a secondary insurance?
A: Yes, functional limitation reporting is a requirement for all patients who have Medicare proper as their primary or secondary insurance. You do not need to complete FLR for patients with Medicare Advantage or supplemental plans.
Q: Do I need to purchase the FLR feature within WebPT?
A: No, your WebPT Membership includes integrated functional limitation reporting.
Q: Where do my billers find the functional limitation reporting data within WebPT?
A: If you are not using the WebPT Billing Service, your billers can locate your functional limitation reporting data on the Billing Report within WebPT. If you are using the WebPT Billing Service, we’ll handle all of this for you.
Q: How many outcome measurement tools should I use?
A: At least one. However, beyond that, you should use as many outcome measurement tools you feel are necessary to assess your patient—the same number you would have used before functional limitation reporting became mandatory. In other words, FLR should not change the way you treat. It’s simply about documenting it.
Q: If my patient is 17% limited, and I believe he will reach 3% limitation at the end of therapy, may I use the same severity modifier for the current and goal statuses?
A: Yes, you can absolutely use the same current and goal status severity modifiers in this situation (CI: At least 1% but less than 20% impaired, limited, or restricted). Just be sure to document your justification clearly within your notes.
Q: Should I complete every aspect of my patient’s prior level of functional ability or just those that correspond to his or her current functional limitation?
A: We recommend being as specific as possible in terms of your patient’s prior level of function. This information will provide greater context to your patient’s history and will help you justify your functional limitation reporting decisions.
Q: If I discharge a patient’s primary functional limitation and start a new primary functional limitation, will the new information show up on the next visit billing report?
A: If you’re a WebPT Member, then yes, the new primary functional limitation reporting data will appear on the next visit billing report.
Q: What type of services does FLR apply to?
A: It is our understanding that functional limitation reporting applies to all outpatient therapy services you bill under Medicare Part B.
Q: Should I bill 97002 every time I complete a progress note with FLR?
A: No, a typical progress note, even one with functional limitation reporting, does not require a 97002 code. In fact, you should only ever bill for a re-exam if one of the following situations apply:
- The professional assessment indicates a significant improvement, decline, or change in the patient’s condition or functional status that was not anticipated in the plan of care for that interval
- New clinical findings
- Failure of the patient to respond to the treatment outlined in the current plan of care
Q: If my patient doesn’t return to therapy, how do I handle FLR?
A: If a patient does not come back to therapy, you should complete a quick discharge. CMS won't penalize you for not including discharge functional limitation reporting requirements as long as you clearly document the situation.
Q: Texas Workers’ Comp follows some of Medicare’s payment policies, and I heard that they were going to soon require functional limitation reporting as well. How do I report FLR for non-Medicare patients within WebPT?
A: WebPT will soon implement changes within the application that will allow you to complete functional limitation reporting for non-Medicare patients. Until this update is complete, you will need to document the G-codes and modifiers manually into your notes and then enter them accordingly into your billing software.
Q: Are you planning to include a calculator that translates OMT scores into corresponding percentages to match the severity modifiers?
A: WebPT has no plans of crosswalking the scores from the OMT into severity modifier percentages. It is imperative that you combine the OMT score with your clinical judgment to decide on the appropriate severity modifier. Not doing so defeats the purpose of FLR.
Have more questions now that functional limitation reporting is mandatory? We’ve got answers. Leave ‘em in the comments below. You can also check out this Q&A PDF from CMS.