Another Point of Confusion for Functional Limitation Reporting with G-Codes
How was the phrase “Surprise, S
urprise, Surprise!” made famous?
The culturally enlightened among you know that this was a phrase uttered frequently by the character Gomer Pyle, played by Jim Neighbors in a 60s sitcom. (I wouldn’t know about TV from the 60s personally, you understand, it is just what I have been told.)
It would be understandable if you answered “CMS”, given the rapid fire, poorly designed, and horribly administered new requirements foisted on therapy providers recently for functional limitation reporting using G-codes.
The latest “Surprise, Surprise, Surprise” that I have found is Question 15 found on page 4 of the Functional Limitation Reporting FAQs:
Q15: ”How do I report functional information when the beneficiary has two plans of care from two different physicians for separate conditions?”
A15: ”Assuming the same provider submits the claim for services under both POCs, only one functional limitation can be reported at a time per discipline. You will need to decide upon which POC Functional Reporting will occur. Treatment days for both conditions are counted towards the reporting frequency – counting each treatment day towards the total number of days the beneficiary received services, under both POCs. Note: It counts as one treatment day when services are received on the same date of service under both POCs.”
What???
Of course, this isn’t to be found in any of the requirements documents or other official guidance. So, even if you have been paying attention and preparing diligently for Functional Limitation Reporting, you are not going to be ready for this new “surprise-surprise-surprise” requirement.
It isn’t terribly uncommon for a therapist to treat a patient under two different Plans of Care. And, I would guess that most providers will not have the systems in place to count visits across multiple cases against a combined 10 visit count for all of the cases. Notice also, that this FAQ doesn’t address what happens to Progress Reporting frequency in this scenario.
Granted, this is a bit of an edge case. Most patients only have one Plan of Care per therapy specialty at a time. But, the patients who do have more than one Plan of Care are usually going to be patients with more severe, complicated problems.
So for a patient being seen by one therapist for two different POCs:
- Track Functional Limitation Reporting for one POC, and not the other.
- Decide any way you would like which case to use for reporting functional impairments. Flip a coin if you would like.
- Count across visits for both cases against the 10 visit minimum for Functional Limitation Reporting purposes.
- Track for minimum Progress Reporting frequency and Plan of Care duration individually for both cases.
So, tracking all of this just got more complicated. And, getting it wrong has real consequences. Which is why we introduced the FLR wizard in our Clinicient platform. The wizard tracks all FLR requirements, walks the therapist through the various decisions needed when it is time to make them, and automatically assigns the correct codes to the claim. It is hard to imagine how someone without a system helping them could succeed.
We are working with our team to modify the FLR Wizard to support this new requirement while we wait for the next surprise from CMS.
To learn more about Clinicient can give you an efficient and easy to use system to manage Functional Limitation Reporting and ensure you get paid by Medicare, schedule a demo today.