Whether you’re just starting out as a Medicare provider—or you’re making the switch from inpatient to outpatient—there’s a lot to keep straight when it comes to the complicated rules, regulations, and policies that govern Original Medicare (which consists of both Part A and Part B).
We compiled an FAQ that answers rehab therapists’ most pressing questions about MIPS and the 2019 final rule.
Last week, the Centers for Medicare and Medicaid Services (CMS) published its 2019 final rule. Clocking in at just over 2,300 pages, the final rule isn’t exactly a light read—especially because the legal lingo can be harder to interpret than Shakespearean verse. Luckily, we have the script—with all its twists and turns—decoded and ready for you to review.
From POC establishment to proper ABN use, here are a veteran PT’s top picks for must-know Medicare compliance facts.
The rehab therapy industry is abuzz with PQRS talk right now. In case you missed it: PQRS as it exists today is dunzo. In 2017, it’ll be replaced with the Merit-Based Incentive Payment System, or MIPS. Unfortunately, though—and yes, it is unfortunate—PTs, OTs, and SLPs are not required to complete MIPS reporting until 2019. (And the jury is still out as to whether they’ll be able to voluntarily participate before then.)
Whether you’re just starting out as a Medicare provider—or you’re making the switch from inpatient to outpatient—there’s a lot to keep straight when it comes to the complicated rules, regulations, and policies that govern Original Medicare (which consists of both Part A and Part B). But if you want to receive reimbursement for your services, you’ve got to know how to navigate the murky Medicare waters.
Is Medicare denying your claims for improper functional limitation reporting? These tricky FLR scenarios might be to blame. Learn how to ensure you get paid.
As of July 1, 2013, the Centers for Medicare and Medicaid Services (CMS) requires that therapists complete functional limitation reporting (FLR)—through the use of G-codes and severity modifiers—on all eligible Medicare Part B patients at the initial evaluation, re-evaluation if applicable, every progress note (minimum of every ten visits), and discharge in order to receive reimbursement for their services. Today, several other private insurance companies also require FLR data as a condition of reimbursement. Good thing WebPT has you covered. Read on to learn how Members can use our totally free, built-in, easy-to-use functional limitation reporting feature.
Prior Level of Function
In the Subjective Tab, you’ll find a section labeled Prior Level of Function. There, you will select your patient’s prior level of function—the areas in which the patient was independently functioning prior to seeking treatment. This information provides supporting evidence and context for your patient’s history. (Note that this section is Medicare required. If you miss this step for a Medicare patient, an alert will prevent you from finalizing your note.)
Current Functional Limitation
Next, you’ll see the Current Functional Limitation section. There, you’ll select your patient’s current functional limitation(s) (check all that apply). This information will also provide supporting evidence and context for your patient. (Note that this section is also Medicare required. If you miss this step for a Medicare patient, an alert will prevent you from finalizing your note.)
Primary Functional Limitation
From there, we’ll prompt you to select your patient’s primary functional limitation category (self care; changing and maintaining body position; mobility: walking and moving around; carrying, moving, and handling objects; or other). Based on this information and the visit type, we’ll autocomplete your G-codes.
Objective Measurement Tools
To identify your patient’s current functional severity and track his or her progress towards the goal, you’ll use the results of an outcome measurement tool (OMT) and your clinical judgement. In this section of the Objective Tab, you’ll be able to select, perform, and score your OMT—and we’ll help you decide which tools to use. There will be a badge next to the outcome measurement tools we feel are most appropriate to use considering your patient’s primary functional limitation (e.g., “M” for mobility: walking and moving around). You can go with our suggestion or choose your own.
Under Status Modifier, you can select the appropriate severity modifier for your patient’s current status (how severe the patient’s limitation is at this moment in time) and projected long-term goal status (how severe you believe the patient’s limitation will be at the end of treatment). This is the first of two opportunities you’ll have to actually apply severity modifiers. If you choose to skip this step here, you must complete it in the Assessment Tab.
Beneath the Assessment/Diagnosis field, you will have a final opportunity to choose your severity modifiers. Here, you can also document the clinical rationale you used to make your selection. This text box will automatically populate based on the outcome measurement tools you selected. (If you already made your severity modifier selections in the Objective Tab but now wish to change them, you may do so using the dropdown menus in this section. Your new selections will replace those in the Objective Tab.)
Problem List and Goals
WebPT will automatically transfer your patient’s primary functional limitation and corresponding goals into the Problem List and Goals test boxes. We will also adjust your goal met percentages in accordance with your patient’s progress. However, you will still need to manually select a goal duration using the dropdown menus.
Your finalized daily note will automatically display your patient’s primary functional limitation, current status, projected goal status, rehab potential, and long-term goal.
On your next progress note (at minimum on your patient’s tenth visit), the system will prompt you to complete functional reporting again. Here, you’ll perform an OMT and—using the results and your clinical judgment—update your patient’s status and severity modifiers as well as verify his or her long-term goal. Just like on the initial evaluation, this information will automatically appear in the problem list and goals boxes.
Once I pick my measures within WebPT, am I stuck with those throughout the year or can I change them? Yes, whichever measures you select will be your measures for the remainder of the year. You have until March 31, 2014, to make your final selection.
On Friday, Medicare released the 2014 specifications for individual PQRS measures. Not much has changed compared to last year; however, there are a few noteworthy differences, which we’ve detailed below. (Please note that there weren’t any major changes for speech language pathologists.)
Confidence and compliance are two words rehab therapists rarely put in the same sentence. Sure, they know that therapy cap requirements, functional limitation reporting, PQRS, the 8-minute rule, and MPPR are all Medicare regulations. But beyond that, memories get a bit fuzzy—and that’s understandable.