The Centers for Medicare and Medicaid Services (CMS) has further clarified the regulations on the new functional limitation reporting requirements that were included in transmittal R2622CP and a new Medicare Learning Network resource. CMS was mandated to collect information on claim forms regarding beneficiaries' function and condition, therapy services furnished, and outcomes achieved on patient function by the Middle Class Tax Relief Act of 2012. All practice settings that provide outpatient therapy services must include this information on the claim form. These new functional limitation reporting requirements were implemented on January 1. To ensure a smooth transition, CMS sets forth a testing period January 1-July 1. After July 1, claims submitted without the appropriate G-codes and modifiers will be returned unpaid.

The major points of clarification include:

• Guidance on using the “Other PT/OT” functional limitation category
• Submission of functional limitation data for more than 1 therapy plan of care
• Reporting instructions for 1-time therapy visits
• Information regarding remittance advice codes to indicate successful submission of the functional reporting data

Additionally, CMS has released revisions to the Medicare Benefit Policy Manual that include the functional limitation reporting requirements (see related article titled "CMS Releases Updates to the Medicare Benefit Policy Manual").  

APTA has posted links to these documents on its functional limitation reporting webpage. The association also has updated the FAQ posted on the webpage, which provides resources to help members meet this new reporting requirement.