Functional Limitation Reporting Under Medicare

The Centers for Medicare and Medicaid Services (CMS) was mandated to collect information regarding the beneficiaries function and condition, therapy services furnished, and outcomes achieved on patient function on the claim forms by the Middle Class Tax Relief Act of 2012. CMS intends to utilize this information in the future to reform payment for outpatient therapy services. All practice settings that provide outpatient therapy services must include this information on the claim form. Specifically, the policy will apply to physical therapy, occupational therapy, and speech-language-pathology (SLP) services furnished in hospitals, critical access hospitals, skilled nursing facilities, comprehensive outpatient rehabilitation facilities (CORFs), rehabilitation agencies, home health agencies (when the beneficiary is not under a home health plan of care), and in private offices of therapists, physicians and nonphysician practitioners.

Under this new rule nonpayable G-codes and modifiers will be included on the claim forms to capture data on the beneficiary's functional limitations:

A. at the outset of the therapy episode;
B. at a minimum every 10th visit; and
C. at discharge.

In addition, the therapist's projected goal for functional status at the end of treatment will be reported on the first claim for services and at the end of the episode. Modifiers will indicate the extent of the severity/complexity of the functional limitation.

The reporting of the functional limitations on the claim form will be implemented on January 1, 2013. To assure smooth transition, CMS sets forth a testing period from January 1, 2013, until July 1, 2013. After July 1, 2013, claims submitted without the appropriate G-codes and modifiers would be returned unpaid.

More resources will be added in the coming months. Check back for these, and more:

  • podcasts on functional limitation reporting
  • additional case examples

General Information

Case Examples

Documentation Guidelines

Education

CMS Resources

Discussion Forum

Tests and Measures Resources

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