Oops! You had your head in the proverbial sand regarding all of this functional limitation reporting mumbo jumbo, and now you need a crash-course—stat! Luckily for you, we’ve put together a quick study guide to help you cram for the big change. Think of it as your FLR CliffsNotes—a condensed summary of this new Centers for Medicare & Medicaid Services (CMS) requirement and what you need to do to stay compliant. So, let’s get to it. Here are the main things you need to know about functional limitation reporting (follow the links to learn more about each item):
- If you do not complete functional limitation reporting, CMS will not reimburse you for your services.
- Functional limitation reporting applies to all practice settings that provide outpatient therapy services.
- You must perform functional limitation reporting on all patients you bill under Medicare Part B.
- The functional limitation reporting mandate only applies to patients using Medicare proper as their primary or secondary insurance. It does not include patients with Medicare replacement or Medicare Advantage plans.
- If you have not already started completing functional limitation reporting for your Medicare patients, you must do so on a patient’s first claim with a date of service after July 1. (Tweet this!)
- You will complete functional limitation reporting using quality data codes known as G-codes, severity modifiers, and therapy modifiers.
- You must complete functional limitation reporting at the onset of therapy (i.e., initial evaluation), at reevaluation (if appropriate), at minimum every tenth visit (progress note), and at discharge.
- As you decide which severity modifier to choose, you must consider both the results of the outcome measurement tool(s) you use as well as your clinical judgment. You absolutely should not crosswalk an OMT score directly to a percentage of impairment—this defeats the purpose of functional limitation reporting.
- You should be honest in your reporting. There is no reason to misrepresent patient progress; in fact, doing so would be detrimental to the therapy industry. (Tweet this!)
- Functional limitation reporting is completely separate from PQRS and the therapy cap. The only thing these regulations have in common is that they all apply to Medicare patients.
- If you issue an Advanced Beneficiary Notice of Noncoverage (ABN) to a Medicare patient, you still must complete functional limitation reporting on that patient—even if you know Medicare will deny the claim, leaving the patient responsible for covering the cost of treatment.
- The easiest, safest way to ensure compliance with functional limitation reporting requirements—and thus, get paid—is implementing a fully integrated FLR solution.
Well, that pretty much covers the nuts and bolts of FLR. (You can pull your head out of the sand now.) Still have questions? Head over to functionallimitation.org, where you can check out a list of frequently asked questions, watch an FLR webinar, and test your knowledge with a ten-question quiz.