Tuesday, May 13, 2014


Recently, an AHCA member posed an interesting Part B therapy documentation and billing scenario related to the therapy Functional Reporting (FR) requirement to which AHCA asked the Centers for Medicare and Medicaid Services (CMS) to provide guidance. The CMS response was that in special situations, the therapist can amend the medical record at a later date. 
Functional reporting gathers data on beneficiary functional limitations during the respective Medicare Part B physical therapy (PT), occupational therapy (OT), or speech-language pathology (SLP) episode of care. CMS implemented the FR requirement in 2013 in response to the provisions of the Middle Class Tax Relief and Jobs Creation Act of 2012 (MCTRJCA).
FR requires that therapists, including those in the SNF setting, report nonpayable G-codes and modifiers to convey information about the beneficiary’s functional status including projected goals throughout the episode of care. FR is required on Part B therapy claims for certain dates of service (DOS) as described below:
  •  At the onset of care (e.g. the DOS of the initial therapy service),
  •  At least once every 10 treatment days,
  •  On the DOS whenever an evaluation or re-evaluation procedure code is submitted on the claim, and
  •  On the DOS of the therapy discharge (exceptions may occur if data unavailable due to unexpected discontinuation of therapy).
Each therapy discipline (PT, OT, and SLP) reports FR codes independently (e.g. they may have different reporting dates depending of the specific discipline’s plan of care). Although the FR G-codes themselves are non-payable, failure to submit the codes at the required reporting periods would result in payment denials for all payable therapy service codes for the therapy services during the noncompliance period.
Therapists are required to document in the patient’s medical record the FR G-codes and severity modifiers that were submitted on the claim that were used to report the patient’s respective current, projected goal, and discharge status. For the severity modifiers, therapists should include a description of how the modifiers were determined. These requirements are applicable for each DOS for which the reporting on the claim is done.

See a summary of the issue and the CMS response HERE. 


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