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When to Report Discharge Codes with Functional Limitation Reporting

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.

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How to Complete Functional Limitation Reporting in WebPT

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.

Initial Evaluation

Subjective Tab
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.)

Prior Level of Function screenshot
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.)

current functional limitation
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.

primary functional limitation
Objective Tab
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.

Functional Reporting

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.

functional reporting
Assessment Tab
Severity Modifiers

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.)

severity modifiers
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.

problem list

Daily Note

Your finalized daily note will automatically display your patient’s primary functional limitation, current status, projected goal status, rehab potential, and long-term goal.

daily note

Progress Note

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.

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Most Frequently Asked Questions from our PQRS Webinar

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.

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Changes to PQRS Measures Specifications for 2014

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.)

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How an EMR Helps You Stay Medicare Compliant

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.

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The Scoop on PQRS

The Centers for Medicare and Medicaid Services (CMS) developed Physician Quality Reporting System (PQRS), which mandates that eligible professionals meet standards for satisfactory reporting. If you are not PQRS-compliant in 2014, CMS will assess penalties. However, we do not yet know what the penalty amount is or how CMS will assess it.

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FLR and PQRS: How Are They Different?

Functional limitation reporting (FLR) and PQRS both fall under the ever-widening umbrella of Medicare regulations, and they both involve outcome measures and data codes. Still, they are completely separate requirements, each with its own set of rules. Confusing, we know. To help you sort out the differences, we’ve put together a short breakdown of each one as well as a detailed compare/contrast chart:

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Functional Limitation Reporting in a Nutshell

Hopefully, you’ve been working your functional limitation reporting (FLR) magic for months now, so you’ve got it down pat. If not, you’re probably running into more than your fair share of claim denials. Don’t worry; we’re here to help. Here are some FLR basics in a convenient chestnut shell. (It is almost that time of the year, after all).

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webinar background

Founder Letter: PQRS 2014

Well, it’s November already, and that means two things: Thanksgiving and Physician Quality Reporting System (PQRS). Sure, PQRS doesn’t involve mouthwatering roasted turkey, savory stuffing, or creamy mashed potatoes, but it has become quite the November tradition for us here at WebPT. You see, this is the time of year that the Centers for Medicare & Medicaid Services (CMS) typically confirms the details of next year’s reporting requirements, thus allowing us to update our PQRS solution (claims- and registry-based reporting) and start our month-long blog and webinar theme of “everything you need to know to be PQRS compliant.”

Unfortunately, this year is shaping up a little differently. As a result of the government shutdown, CMS delayed its November 1 meeting to discuss the 2014 Physician Fee Schedule Proposed Rule—which includes potential PQRS changes—until at least the middle of this month. And until they meet, we won’t know much about what PQRS 2014 will truly entail in terms of reporting requirements, measures, penalties, and incentives—let alone when the government will actually finalize the Proposed Rule. This means that as of today, no one knows for sure:

  • which measures therapists must report
  • how many measures therapists must report
  • whether there will be compliance incentives
  • what penalties will be associated with noncompliance
  • what percentage of patients for whom therapists must complete PQRS reporting

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What PQRS Could Look Like in 2014

On July 19, 2013, the Centers for Medicare & Medicaid Services (CMS) published the 2014 Medicare Physician Fee Schedule (MPFS) Notice of Proposed Rulemaking (NPRM) in the Federal Register. According to this summary, most of the policies were open for comment until September 6, 2013 and, pending final decisions (which hopefully will occur this month), will take effect on January 1, 2014.

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