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  • Functional Limitation Reporting Tip: Submit Claims in Sequence

    To avoid payment challenges to functional limitation reporting when you file for outpatient Medicare services provided beginning July 1, submit your claims in sequence. As a reminder, the testing phase of the functional limitation reporting requirement ends June 30, after which outpatient Medicare claims will be returned unpaid if they don't include the required functional limitation reporting.

    On each beneficiary's first treatment date on or after July 1, physical therapists must report the appropriate functional G-codes and corresponding modifiers on the claim form (editor's note: see update below). This includes beneficiaries for whom functional reporting occurred during the testing period. Once Medicare receives the claim, its claims processing system will open a therapy reporting episode and start counting to the next 10 treatment dates of service per the progress reporting period, starting with the first claim containing the appropriate current and goal status G-codes and corresponding modifiers submitted on or after July 1. Submitting claims in sequence will facilitate tracking of treatment dates for the different reporting periods.

    For more information and resources on functional limitation reporting, please see APTA's Functional Limitation Reporting webpage, which includes links to PTNow's resources on appropriate tests and measures, and APTA's Functional Limitation Discussion Forum.

    Update - June 18, 2013: Some of the information reported above is obsolete, in light of recent changes by CMS. Learn more here: CMS Changes July 1 Functional Limitation Reporting Instructions for Current Patients.


    • As if the burden of this program isn't enough? To now have to "start over" on July 1st with all your medicare patients after the trial period has begun...just plain ridiculous. Tail wagging the dog as usual with this stuff....

      Posted by Michael Vacon on 6/7/2013 3:35 PM

    • Medicare does not process the claims in order as it is. If we hit the max and have to add KX to the 3rd claim of 3, they will process them backwards and reject the 1st claim as over the max instead. So we have to go back and add KX to the whole batch. This could be a problem with the 10 treatments if they process number 8 and 9 after number 10 too? (We bill by paper)

      Posted by Debbe on 6/7/2013 8:24 PM

    • Is APTA 100% sure of this? So what was the sense of starting G codes before July 1st? This is beyond absurd - it seems obvious that this system is not well thought out - What a surprise!

      Posted by Roslyn Sofer on 6/7/2013 11:37 PM

    • It's unclear if July 1 is the required date for all new patients to include g codes and established patients with g code submission will just continue on? Someone needs to clarify this ongoing situation ??

      Posted by Gail on 6/8/2013 8:06 AM

    • There will be a lot of claims denied after July 1st. What about patients receiving care by a PTA on July 1st? We can see many out patient clinics taking a serious hit on payment from medicare this summer. I agree with the other comments outlined above. Why did we even have a trial period?

      Posted by Chad on 6/9/2013 2:41 PM

    • No doubt this PQRS and FLR business is a major headache, but I don't understand the complaints about the pre-July 1st lead-up. It seems obvious that the time prior to 7/1 is to allow practices the time to get procedures in place for the data gathering and reporting and to work out the bugs. We have to be ready to go "live" on 7/1, with the time prior being a dress rehearsal.

      Posted by Todd on 6/9/2013 6:33 PM

    • How will this affect hospital based outpatient clinics since we submit claims monthly?

      Posted by Iris on 6/10/2013 10:32 AM

    • CMS has informed APTA and stated on last week's physician, nurses and allied health professionals open door forum call that providers will need to report functional limitation data (G codes) on the first date of service in July, even if they have already been reporting G codes prior to July. We recognize that this is burdensome for providers and we have conveyed your concerns to CMS officials to see if anything can be done to reduce the burden. As soon as we get more information, we will disseminate it to our members.

      Posted by News Now Staff on 6/10/2013 11:57 AM

    • I am curious if this resets the 10 th visit progress note cycle as well? We have been reporting G codes since March 1st and our current patients are in a cycle that makes sense - all learning curve is over for the staff - the electronic submission is going well - the EMR is set up.... We are ready for July 1st, but have to start the current patients at day 1 again?! Ridiculous!

      Posted by Amber Nye -> AKS\<F on 6/10/2013 2:40 PM

    • Can we re-report the functional limitation data that we've already reported the last week in June?

      Posted by Gary Lynch -> >FV`< on 6/10/2013 3:15 PM

    • The count of the 10th visit is where the biggest headache will come for our clinic. CMS is going to start counting 10 visits from the first visit on or after July 1st... doesn't matter if that patient is really on their 2nd or 9th visit. Then you have to report on what CMS is calling their "10th visit" from the start of July. How many clinics do you think are going to get denied for making a mistake on that date or claim number for the 10th visit progress G Code?

      Posted by Christi on 6/11/2013 12:07 PM

    • If the PT does a "Physician Letter" can you charge for a re-evaluation and if so would you need to use the functional G codes on the re-evaluation.

      Posted by MONA GRAHAM on 6/12/2013 5:21 PM

    • APTA continues to await the release of the Medicare functional limitation reporting FAQ document which should provide additional details about how therapists should handle reporting for current patients beginning on July 1, 2013. As soon as we get more information, we will disseminate it to our members.

      Posted by News Now Staff on 6/13/2013 4:41 PM

    • For Medicare patients where G codes and modifiers have been documented by the therapist and added to the claim prior to July 1, would CMS allow the initial/ current G code and modifiers to be reported on the first visit claim in July (based on prior documentation by the PT) without requiring the physical therapist to have documented the G code and modifier on that date of service? Then a PTA could see the patient that first visit in July and the patient could keep their prior 10th visit schedule: CMS won't mind getting G codes and modifiers sooner than the 10th visit.

      Posted by Christine Caesar on 6/13/2013 9:33 PM

    • Wouldn't it be nice if providers could concentrate on treating patients rather than appeasing the government?

      Posted by Carol Barker on 6/14/2013 4:26 PM

    • On the 10th visit, is it supposed to be the PT or PTA that does the reassessment for functional reporting?

      Posted by Chad Brandon on 8/21/2013 9:35 AM

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