What were G-codes?

G-codes were quality data codes that rehab therapy providers—including eligible physical therapists, occupational therapists, and speech-language pathologists—included on their Medicare claim forms to fulfill requirements for Functional Limitation Reporting (FLR). CMS originally used this code set to track information about Medicare beneficiaries’ function and condition. G-codes were also used to report for PQRS—a defunct quality-reporting program—until January 1, 2017.

Effective January 1, 2019, providers no longer have to report G-codes or severity modifiers for Medicare FLR. CMS eliminated all Medicare FLR requirements in the 2019 physician fee schedule, stating that the program placed undue burden on participants. However, G-codes will stick around for at least another year. CMS wanted to give providers additional time to phase out FLR G-codes and avoid billing mishaps, so Medicare FLR is optional during 2019.

Because CMS is retaining the FLR G-codes for at least another year, those who participate in MIPS in 2019 will be allowed to use six G-codes when reporting some Quality measures: G8980, G8983, G8986, G8989, G8992, and G8995.

Below is a comprehensive list of the 42 G-codes used in FLR (organized by category and specialty), followed by a list of now-discontinued severity modifiers, and still-active therapy modifiers. Further down the page, you’ll find the full list of G-codes for the PQRS program, which, as noted above, is no longer in effect.

What were functional limitation reporting G-codes?

First off, let’s cover some FLR basics. Functional Limitation Reporting was a Centers for Medicare & Medicaid Services (CMS) reporting regulation for physical therapists, occupational therapists, and speech-language pathologists who provided outpatient therapy services to Medicare beneficiaries. Medicare would not reimburse providers if claims lacked FLR data.

The goal of FLR was to establish an evidence-based connection between rehab therapy treatment and patient progress. CMS initially hoped to use the information it collected from FLR (and its accompanying G-codes) to get a better sense of the Medicare beneficiary population, evaluate the effectiveness of the therapy treatment those patients received, and develop future payment structures for therapy services. But over time, CMS realized that the data it was collecting through FLR wasn’t suited for any of those purposes—which was part of why it discontinued the program.

FLR Completion

To comply with FLR, therapists had to report functional limitation data in the form of G-codes—along with the corresponding severity modifiers and therapy modifiers—at the initial examination, at minimum every tenth visit (or progress note), and at discharge for all patients who had Medicare proper as their primary or secondary insurance. Therapists did not need to complete FLR for patients who had Medicare replacement or Medicare Advantage (MA) plans.

Therapists could only report functional limitation data on each patient's’ primary functional limitation—in other words, the main reason the patient sought rehabilitative services. However, therapists were permitted to treat as many limitations as was appropriate.

Medicare documentation and claims needed to include two FLR G-codes—each followed by a severity modifier and a therapy modifier—for a total of six FLR codes.

To see what functional limitation reporting was like in action, check out this post.

Medicare Claim Forms

Therapists who saw Medicare patients had to submit FLR G-codes as separate line items on Medicare claims. First, they entered the regular CPT codes (as on a normal claim) to indicate the treatment they provided. Then, they submitted each G-code with a nominal charge ($0.01). For claims that were longer than one page, therapists entered the total for item 27 on the last CMS-1500 claim form.

Reimbursements

To ensure that therapists received proper reimbursement for their services, WebPT recommended that they adhere to the following tips from now-retired compliance expert Tom Ambury:

  1. Create clear, detailed documentation during each patient’s episode of care.
  2. Audit your clinic’s documentation process regularly to ensure defensibility.
  3. File your claims in a timely manner.
  4. Stay current on reporting regulations, requirements, and legislation.
  5. Have a knowledgeable and trustworthy source for compliance information in case you have a question.

Rejections

If providers received rejection letters in response to their submitted claims because they omitted FLR data, there wasn’t much they could do—unless they were in a situation in which they actually did identify their patient’s primary functional limitation, completed an outcome measurement tool, and documented the resulting episode of care appropriately, but inadvertently omitted the corresponding G-codes and severity modifiers. If—and only if—that was the case, providers were permitted to go back, create an addendum with the missing codes, and re-submit their claims. However, addendums were liable to throw up red flags for Medicare. To learn more about the appropriateness of creating addendums, therapists were encouraged to contact their local MAC or a compliance expert. Under no circumstances were therapists allowed to go back and change their documentation to meet FLR requirements.

Now, on to the codes. Just to reiterate: these G-codes and severity modifiers are no longer mandatory on Medicare claims. CMS will recognize and accept claims that contain G-codes and severity modifiers until at least 2020, but there is no penalty for their omission.

Physical Therapy and Occupational Therapy Codes

Mobility: Walking & Moving Around

G-Code

Description

Short Descriptor

G8978 Mobility

Walking and moving around functional limitation, current status, at therapy episode outset, and at reporting intervals

Mobility current status

G8979 Mobility

Walking and moving around functional limitation, projected goal status, at therapy episode outset, at reporting intervals, and at discharge or to end reporting

Mobility goal status

G8980 Mobility

Walking and moving around functional limitation, discharge status, at discharge from therapy or to end reporting

Mobility discharge status

Changing & Maintaining Body Position

G-Code

Description

Short Descriptor

G8981

Changing and maintaining body position functional limitation, current status, at therapy episode outset, and at reporting intervals

Body position current status

G8982

Changing and maintaining body position functional limitation, projected goal status at therapy episode outset, at reporting intervals, and at discharge or to end reporting

Body position goal status

G8983

Changing and maintaining body position functional limitation, discharge status, at discharge from therapy or to end reporting

Body position discharge status

Carrying, Moving & Handling Objects

G-Code

Description

Short Descriptor

G8984

Carrying, moving, and handling objects functional limitation, current status, at therapy episode, and at reporting intervals

Carry current status

G8985

Carrying, moving, and handling objects functional limitation, projected goal status, at therapy episode outset, at reporting intervals, and at discharge or to end reporting

Carry goal status

G8986

Carrying, moving, and handling objects functional limitation, discharge status, at discharge from therapy or to end reporting

Carry discharge status

Self Care

G-Code

Description

Short Descriptor

G8987

Self care functional limitation, current status, at therapy episode outset, and at reporting intervals.

Self care current status

G8988

Self care functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting

Self care goal status

G8989

Self care functional limitation, discharge status, at discharge from therapy or to end reporting

Self care discharge status

Other PT/OT Primary Functional Limitation

G-Code

Description

Short Descriptor

G8990

Other physical or occupational primary functional limitation, current status, at therapy episode outset, and at reporting intervals

Other PT/OT current status

G8991

Other physical or occupational primary functional limitation, projected goal status, at therapy episode outset, at reporting intervals, and at discharge or to end reporting

Other PT/OT goal status

G8992

Other physical or occupational primary functional limitation, discharge status, at discharge from therapy to end reporting

Other PT/OT discharge status

Other PT/OT Subsequent Functional Limitation

G-Code

Description

Short Descriptor

G8993

Other physical or occupation subsequent functional limitation, current status, at therapy episode outset, and at reporting intervals

Sub PT/OT current status

G8994

Other physical or occupational subsequent functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting

Sub PT/OT goal status

G8995

Other physical or occupational subsequent functional limitation, discharge status, at discharge from therapy or to end reporting

Sub PT/OT discharge status

Speech-Language Pathology G-Codes

Swallowing

G-Code

Description

Short Descriptor

G8996

Swallowing functional limitation, current status, at therapy episode outset, and at reporting intervals

Swallow current status

G8997

Swallowing functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting

Swallow goal status

G8998

Swallowing functional limitation, discharge status, at discharge from therapy or to end reporting

Swallow discharge status

Motor Speech

G-Code

Description

Short Descriptor

G8999

Motor speech functional limitation, current status, at therapy episode outset, and at reporting intervals

Motor speech current status

G9186

Motor speech functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting

Motor speech goal status

G9158

Motor speech functional limitation, discharge status, at discharge from therapy or to end reporting

Motor speech discharge status

Spoken Language Comprehension

G-Code

Description

Short Descriptor

G9159

Spoken language comprehension functional limitation, current status, at therapy episode outset, and at reporting intervals

Spoken language comprehension current status

G9160

Spoken language comprehension functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting

Spoken language comprehension goal status

G9161

Spoken language comprehension functional limitation, discharge status, at discharge from therapy or to end reporting

Spoken language comprehension discharge status

Spoken Language Expression

G-Code

Description

Short Descriptor

G9162

Spoken language expression functional limitation, current status, at therapy episode outset, and at reporting intervals

Spoken language expression current status

G9163

Spoken language expression functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting

Spoken language expression goal status

G9164

Spoken language expression functional limitation, discharge status, at discharge from therapy or to end reporting

Spoken language expression discharge status

Attention

G-Code

Description

Short Descriptor

G9165

Attention functional limitation, current status, at therapy episode outset, and at reporting intervals

Attention current status

G9166

Attention functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting

Attention goal status

G9167

Attention functional limitation, discharge status, at discharge from therapy or to end reporting

Attention discharge status

Memory

G-Code

Description

Short Descriptor

G9168

Memory functional limitation, current status, at therapy episode outset, and at reporting intervals

Memory current status

G9169

Memory functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting

Memory goal status

G9170

Memory functional limitation, discharge status, at discharge from therapy or to end reporting

Memory discharge status

Voice

G-Code

Description

Short Descriptor

G9171

Voice functional limitation, current status, at therapy episode outset, and at reporting intervals

Voice current status

G9172

Voice functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting

Voice goal status

G9173

Voice functional limitation, discharge status, at discharge from therapy or to end reporting

Voice discharge status

Other Speech Language Pathology

G-Code

Description

Short Descriptor

G9174

Other speech language pathology functional limitation, current status, at therapy episode outset, and at reporting intervals

Other speech language pathology current status

G9175

Other speech language pathology functional limitation, projected goal status, at therapy episode outset, at reporting intervals, at discharge or to end reporting

Other speech language pathology goal status

G9176

Other speech language pathology functional limitation, discharge status, at discharge from therapy or to end reporting

Other speech language pathology discharge status

Functional Limitation Severity Modifier Codes

Modifier

Impairment Limitation Restriction

CH

0% impaired, limited, or restricted

CI

At least 1% but less than 20% impaired, limited, or restricted

CJ

At least 20% but less than 40% impaired, limited, or restricted

CK

At least 40% but less than 60% impaired, limited, or restricted

CL

At least 60% but less than 80% impaired, limited, or restricted

CM

At least 80% but less than 100% impaired, limited, or restricted

CN

100% impaired, limited, or restricted

Functional Limitation Therapy Modifier Codes

Therapy modifiers are still actively used; they indicate the type of therapy services that are provided to a patient.

Modifier

Services Delivered Under Outpatient POC

GO

Occupational Therapy

GP

Physical Therapy

GN

Speech-Language Pathology

What were FLR outcome measurement tools?

Outcome measurement tools are objective tests that therapists used to help determine the severity and complexity of their patients’ functional limitations. Here are some of the outcome measurement tools that were available for rehab therapists to use to satisfy FLR requirements (please note that therapists still use these tools to set, and monitor progress toward, patient goals outside of FLR reporting):

Physical and Occupational Therapists

General Function

Balance

Lower Extremity

Spine

Upper Extremity

Barthel Index

ABC Scale

Lower Extremity Functional Scale

Neck Disability Index Questionnaire

DASH

Dynamic Gait Index

Berg

Oswestry Low Back Pain Disability Questionnaire

Hand Profile

Falls Efficacy Scale

Fullerton Advanced Balance Sale

The Quebec Back Pain Disability Scale

Shoulder Pain and Disability Questionnaire

Functional Reach Test

Motion Sensitivity Score

Upper Extremity Functional Index

Mini Mental State Exam

Tinetti

Upper Extremity Quick DASH

TUG

Speech Language Pathologists

Alaryngeal Communication

Attention

Augmentative-Alternative Communication

Fluency

Functional Communication Measures

Memory

Motor Speech

Pragmatics

Problem Solving

Reading

Spoken Language Comprehension

Spoken Language Expression

Swallowing

Voice

Writing

Voice Following Tracheostomy

Download the Therapists’ Guide to FLR now.

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What were Physician Quality Reporting System G-codes?

Prior to the consolidation of PQRS into the Merit-based Incentive Payment System (MIPS) in January 2017, rehab therapists used a separate set of G-codes to report on PQRS measures. These G-codes were totally unrelated to those used for functional limitation reporting.

Below are the G-codes and other quality data codes (QDCs) that were associated with the 2016 PQRS measures applicable to each specialty (physical therapy, occupational therapy, and speech-language pathology).

Click here for more information about PQRS.

Physical Therapy

#126 Diabetes Foot/Ankle Evaluation

G8404: Lower extremity neurological exam performed and documented

G8405: Lower extremity neurological exam not performed

#127 Diabetes - Footwear Evaluation

G8410: Footwear evaluation performed and documented

G8416: Clinician documented that patient was not an eligible candidate for footwear evaluation measure

G8415: Footwear evaluation was not performed

#128 BMI Screening

G8420: BMI is documented within normal parameters and no follow-up plan is required

G8417: BMI is documented above normal parameters and a follow-up plan is documented

G8418: BMI is documented below normal parameters and a follow-up plan is documented

G8422: BMI not documented, documentation states that the patient is not eligible for BMI calculation

G8938: BMI is documented as being outside of normal limits, follow-up plan is not documented, documentation states that the patient is not eligible

G8421: BMI not documented and no reason is given

G8419: BMI documented outside normal parameters, no follow-up plan documented, no reason given

#130 Current Medications

G8427: Eligible professional attests to documenting in the medical record they obtained, updated, or reviewed the patient’s current medications

G8430: Eligible professional attests to documenting in the medical record the patient is not eligible for a current list of medications being obtained, updated, or reviewed by the eligible professional

G8428: Current list of medications not documented as obtained, updated, or reviewed by the eligible professional, reason not given

#131 Pain Assessment

G8730: Pain assessment documented as positive using a standardized tool AND a follow-up plan is documented

G8731: Pain assessment using a standardized tool is documented as negative, no follow-up plan required

G8442: Pain assessment NOT documented as being performed, documentation states that the patient is not eligible for a pain assessment using a standardized tool

G8939: Pain assessment documented as positive, follow-up plan not documented, documentation states that the patient is not eligible

G8732: No documentation of pain assessment, reason not given

G8509: Pain assessment documented as positive using a standardized tool, follow-up plan not documented, reason not given

#154 Falls Risk Assessment

CPT II 3288F AND 1100F: Falls risk assessment documented AND
patient screened for future fall risk; documentation of two or more falls in the past year or any fall with injury in the past year

CPT II 3288F-1P AND 1100F: Documentation of medical reason(s) for not completing a risk assessment for falls AND
Patient screened for future fall risk; documentation of two or more falls in the past year or any fall with injury in the past year

CPT II 1101F: Patient screened for future fall risk; documentation of no falls in the past year or only one fall without injury in the past year

CPT II 1101F-8P: No documentation of falls status

CPT II 3288F-8P AND 1100F: Falls risk assessment not completed, reason not otherwise specified AND patient screened for future fall risk; documentation of two or more falls in the past year or any fall with injury in the past year

#155 Falls POC

CPT II 0518F: Falls plan of care documented

CPT II 0518F-1P: Documentation of medical reason(s) for no plan of care for falls

CPT II 0518F-8P: Plan of care not documented, reason not otherwise specified

#182 Functional Outcome Assessment

G8539: Functional outcome assessment documented as positive using a standardized tool AND a care plan based on identified deficiencies on the date of the functional outcome assessment is documented

G8542: Functional outcome assessment using a standardized tool is documented; no functional deficiencies identified, care plan not required

G8942: Functional outcome assessment using a standardized tool is documented within the previous 30 days and care plan based on identified deficiencies on the date of the functional outcome assessment is documented

G8540: Functional outcome assessment NOT documented as being performed, documentation states that the patient is not eligible for a functional outcome assessment using a standardized tool

G9227: Functional outcome assessment documented, care plan not documented, documentation states that the patient is not eligible for a care plan

G8541: Functional outcome assessment using a standardized tool not documented, reason not given

G8543: Documentation of a positive functional outcome assessment using a standardized tool; care plan not documented, reason not given

Occupational Therapy

#128 BMI Screening

G8420: BMI is documented within normal parameters and no follow-up plan is required

G8417: BMI is documented above normal parameters and a follow-up plan is documented

G8418: BMI is documented below normal parameters and a follow-up plan is documented

G8422: BMI not documented, documentation states that the patient is not eligible for BMI calculation

G8938: BMI is documented as being outside of normal limits, follow-up plan is not documented, documentation states that the patient is not eligible

G8421: BMI not documented and no reason is given

G8419: BMI documented outside normal parameters, no follow-up plan documented, no reason given

#130 Current Medications

G8427: Eligible professional attests to documenting in the medical record they obtained, updated, or reviewed the patient’s current medications

G8430: Eligible professional attests to documenting in the medical record the patient is not eligible for a current list of medications being obtained, updated, or reviewed by the eligible professional

G8428: Current list of medications not documented as obtained, updated, or reviewed by the eligible professional, reason not given

#131 Pain Assessment

G8730: Pain assessment documented as positive using a standardized tool AND a follow-up plan is documented

G8731: Pain assessment using a standardized tool is documented as negative, no follow-up plan required

G8442: Pain assessment NOT documented as being performed, documentation states that the patient is not eligible for a pain assessment using a standardized tool

G8939: Pain assessment documented as positive, follow-up plan not documented, documentation states that the patient is not eligible

G8732: No documentation of pain assessment, reason not given

G8509: Pain assessment documented as positive using a standardized tool, follow-up plan not documented, reason not given

#134 Preventative Clinical Depression Screening

G8431: Screening for clinical depression is documented as being positive AND a follow-up plan is documented

G8510: Screening for clinical depression is documented as negative, a follow-up plan is not required

G8433: Screening for clinical depression not documented, documentation stating the patient is not eligible

G8940: Screening for clinical depression documented as positive, a follow-up plan not documented, documentation stating the patient is not eligible

G8432: Clinical depression screening not documented, reason not given

G8511: Screening for clinical depression documented as positive, follow-up plan not documented, reason not given

#154 Falls Risk Assessment

CPT II 3288F AND 1100F: Falls risk assessment documented AND
patient screened for future fall risk; documentation of two or more falls in the past year or any fall with injury in the past year

CPT II 3288F-1P AND 1100F: Documentation of medical reason(s) for not completing a risk assessment for falls AND
Patient screened for future fall risk; documentation of two or more falls in the past year or any fall with injury in the past year

CPT II 1101F: Patient screened for future fall risk; documentation of no falls in the past year or only one fall without injury in the past year

CPT II 1101F-8P: No documentation of falls status

CPT II 3288F-8P AND 1100F: Falls risk assessment not completed, reason not otherwise specified AND patient screened for future fall risk; documentation of two or more falls in the past year or any fall with injury in the past year

#155 Falls POC

CPT II 0518F: Falls plan of care documented

CPT II 0518F-1P: Documentation of medical reason(s) for no plan of care for falls

CPT II 0518F-8P: Plan of care not documented, reason not otherwise specified

#181 Elder Maltreatment Screen and Follow-Up

G8733: Elder maltreatment screen documented as positive AND a follow-up plan is documented

G8734: Elder maltreatment screen documented as negative, follow-up is not required

G8535: Elder maltreatment screen not documented; documentation states that patient is not eligible for the elder maltreatment screen

G8941: Elder maltreatment screen documented as positive, follow-up plan not documented, documentation states that the patient is not eligible for follow-up plan

G8536: No documentation of an elder maltreatment screen, reason not given

G8735: Elder maltreatment screen documented as positive, follow-up plan not documented, reason not given

#182 Functional Outcome Assessment

G8539: Functional outcome assessment documented as positive using a standardized tool AND a care plan based on identified deficiencies on the date of the functional outcome assessment is documented

G8542: Functional outcome assessment using a standardized tool is documented; no functional deficiencies identified, care plan not required

G8942: Functional outcome assessment using a standardized tool is documented within the previous 30 days and care plan based on identified deficiencies on the date of the functional outcome assessment is documented

G8540: Functional outcome assessment NOT documented as being performed, documentation states that the patient is not eligible for a functional outcome assessment using a standardized tool

G9227: Functional outcome assessment documented, care plan not documented, documentation states that the patient is not eligible for a care plan

G8541: Functional outcome assessment using a standardized tool not documented, reason not given

G8543: Documentation of a positive functional outcome assessment using a standardized tool; care plan not documented, reason not given

#226 Tobacco Use Screen and Cessation Intervention

CPT II 4004F: Patient screened for tobacco use AND received tobacco cessation intervention (counseling, pharmacotherapy, or both), if identified as a tobacco user

CPT II 1036F: Current tobacco non-user

4004F-1P: Documentation of medical reason(s) for not screening for tobacco use (e.g., limited life expectancy or other medical reasons)

4004F-8P: Tobacco screening OR tobacco cessation intervention not performed, reason not otherwise specified

Speech-Language Pathology

#130 Current Medications

G8427: Eligible professional attests to documenting in the medical record they obtained, updated, or reviewed the patient’s current medications

G8430: Eligible professional attests to documenting in the medical record the patient is not eligible for a current list of medications being obtained, updated, or reviewed by the eligible professional

G8428: Current list of medications not documented as obtained, updated, or reviewed by the eligible professional, reason not given

#131 Pain Assessment

G8730: Pain assessment documented as positive using a standardized tool AND a follow-up plan is documented

G8731: Pain assessment using a standardized tool is documented as negative, no follow-up plan required

G8442: Pain assessment NOT documented as being performed, documentation states that the patient is not eligible for a pain assessment using a standardized tool

G8939: Pain assessment documented as positive, follow-up plan not documented, documentation states that the patient is not eligible

G8732: No documentation of pain assessment, reason not given

G8509: Pain assessment documented as positive using a standardized tool, follow-up plan not documented, reason not given

#226 Tobacco Use Screen and Cessation Intervention

CPT II 4004F: Patient screened for tobacco use AND received tobacco cessation intervention (counseling, pharmacotherapy, or both), if identified as a tobacco user

CPT II 1036F: Current tobacco non-user

4004F-1P: Documentation of medical reason(s) for not screening for tobacco use (e.g., limited life expectancy or other medical reasons)

4004F-8P: Tobacco screening OR tobacco cessation intervention not performed, reason not otherwise specified

Do I still have to submit G-codes in 2019?

G-codes are no longer mandatory—for PQRS or for FLR—and PTs, OTs, and SLPs no longer have to include them on Medicare claims. FLR G-codes are now optional through 2019, and CMS hopes to delete them entirely at the beginning of 2020.

Because CMS is retaining these G-codes, providers may use six of them (G8980, G8983, G8986, G8989, G8992, and G8995) for MIPS quality reporting.


Don’t face Medicare compliance alone.


Heidi Jannenga

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