Lately, there’s been a bit of confusion surrounding Medicare’s requirements for submitting functional limitation reporting (FLR) discharge codes. Due to a “glitch” in the way Medicare processes claims containing FLR data, some therapists have received claim denials for cases involving tricky discharge reporting scenarios. So, we’ve put together a guide to address some common head-scratching situations. Read on to learn when you need to discharge and when you don’t.

Patient Self-Discharges and Returns After 60 or More Days

If a patient unexpectedly discontinues therapy, Medicare will automatically discharge the therapy reporting episode 60 days after the last recorded date of service. At that point, the patient has a clean slate as far as FLR goes. If the patient returns to therapy, there is no need to report discharge FLR data for the patient’s original primary functional limitation. Simply perform an initial examination and begin reporting FLR as if you were treating a new patient.

Patient Self-Discharges and Returns Within 60 Days to Treat the Same Functional Limitation

If a patient self-discharges and returns within 60 to receive treatment for the same functional limitation for which they previously received treatment, there is no need to complete a discharge note or submit discharge codes. Simply resume treating, documenting, and reporting FLR data as normal.

Patient Self-Discharges and Returns Within 60 Days to Treat a Different Functional Limitation

According to the APTA, if a patient self-discharges and returns to therapy within 60 days to receive treatment for a different functional limitation, you must discharge the original functional limitation during the patient’s first visit back to therapy. If you use WebPT, you will still assess and document the patient’s new functional limitation during that patient’s initial examination, even though the only FLR data you’ll actually submit for that visit is the discharge data for the patient’s original functional limitation. Then, you’ll begin reporting FLR data on the patient’s new functional limitation during the patient’s next date of service (his or her second visit back to therapy).

Patient is Receiving Treatment for Two Different Cases From Two Different Therapists in the Same Clinic

If a patient seeks treatment for two different diagnoses (and two different functional limitations) from two different therapists within the same clinic, the two therapists must determine which of the two cases represents the patient’s true primary functional limitation. Based on that decision, one therapist will then discharge his or her primary functional limitation and the other will take “ownership” of FLR for that particular patient. However, the two therapists must collaborate and make sure their respective therapy goals align even though one therapist isn’t reporting FLR. For example, if the reporting therapist is treating for mobility and the non-reporting therapist is treating for self-care, the non-reporting therapist must weave elements of mobility treatment into his or her plan of care for the patient.

If, at the outset of treatment, both therapists agree on a single primary functional limitation (e.g., self care), one therapist will report all three sets of G-codes and severity modifiers (e.g., current status, projected goal status, and discharge status) at initial evaluation. Then, that therapist will continue to treat as normal without reporting any FLR data.


Have you received any claim denials related to discharge code reporting? What happened? Share your thoughts and questions in the comments section below.