The functional limitation reporting (FLR) requirements were discontinued as of January 1, 2019, per the 2019 physician fee schedule ruling. The Centers for Medicare and Medicaid Services (CMS) confirmed in March 2019 (.pdf) that for dates of service on or after January 1, 2019, "Medicare no longer requires the functional reporting nonpayable HCPCS G-codes and severity modifiers…on claims for therapy services." For Medicare patients whose episode of care began in 2018 and continues into 2019, this clarifies that providers don't need to continue documenting and submitting FLR data for services provided to these patients in 2019.
One reason CMS gave for the decision to end FLR was strong APTA regulatory and legislative advocacy efforts highlighting the heavy administrative burden despite little contribution to improved patient care. A research study published in PTJ examines FLR reporting data, concluding that the program's usefulness was severely limited.
CMS will retain the set of 42 nonpayable HCPCS G-codes until 2020, to allow time for therapy providers and other private insurers who currently use these codes for functional reporting to update their billing systems and policies. This will avoid unnecessary delays or denials of claims that inadvertently contain the codes during 2019. In addition, APTA staff is monitoring commercial payers' policy change notices and clinical bulletins for any announcements that private payers are ending their G-code policies, and the association will alert members when it hears of changes. If you become aware of a payer ending their G-code policy, please notify APTA at firstname.lastname@example.org.
For Medicare patients whose episode of care began in 2018 and continues into 2019: Medicare Administrative Contractors may expect providers to continue documenting and submitting functional limitation data until the patient is discharged. Until CMS issues guidance stating otherwise, it is advisable to continue to comply with FLR requirements for these Medicare patients.
Frequently Asked Questions
FAQ: General Information About Functional Limitation Reporting
FAQ: Documentation of the Functional Codes
FAQ: G-Code Billing and Claims Submission
Problems With Reporting
Some physical therapists (PTs) have experienced processing delays and errors on functional limitation reporting claims. PTs should first review their claims for common errors and mistakes. (Use the FAQs above and the resources below.) If after doing so, APTA assistance or guidance is needed, please complete the online complaint form below. A member of APTA staff will contact you.
Read APTA's Letter to CMS Regarding FLR Challenges Faced by Health Care Provider (.pdf) - 5/2/14
Read PT in Motion News: UnitedHealthcare Delays Requirement for Functional Limitation Reporting - 8/4/14