I feel like I start every conversation lately with, “I don’t think CMS is intentionally evil, but…” And, so it is today. I don’t think CMS is intentionally evil, but the latest developments in Functional Limitation Reporting are causing providers claim denials simply because CMS made the whole process too complex.
Unintended Discharges
The current issue is how CMS handles Unintended Discharges (or Self-discharged patients). It turns out that the Medicare Contractors (MACS) are having difficulty processing claims for patients with multiple plans of care within the same discipline if there was an unplanned discharge on a prior plan of care. In other words, when a patient self-discharges and returns to therapy within some limited timeframe, the MAC denies all new claims because they still expect FLR reporting on the old Plan of Care.
This was not intended because CMS was quite clear that discharge FLR codes were required only “if data is available.” So, if data is not available at the time of discharge from the therapy episode of care, there will never be a problem, right? WRONG. There is no problem most of the time. But, if that patient returns for another episode of therapy at the same facility from the same discipline, there can be a problem.
Denials Are Mounting
As the denials began to mount, MAC’s began to clarify they are unable to process a new plan of care with a different functional limitation without discharging the previous functional limitation for some undetermined period of time.. Just this past week, Noridian, one of the large Medicare Contractors published a bulletin to clarify that period of time to be 60 days for their beneficiaries. Some have assumed this is the policy for all of CMS and we certainly hope so, but not all MACs have published policy, yet.
What we do know is that any provider who is seeing a return patient, within the same discipline but for a new functional limitation, should find a way to submit discharge codes on the prior functional limitation before submitting a new Plan of Care, if you want to avoid denied claims. How far back should you go? If you are not a Noridian provider, to be safe, you may want to look back as far as 90 days.
Watch a Quick Video Presentation
For a bureaucratic data collection exercise, Functional Limitation Reporting has caused major headaches and mass confusion, not just for providers, but for MACs as well. If you are struggling to make sense of what is going on, I encourage you to watch a quick video presentation that reviews the requirements around tracking functional limitations for multiple plans of care and shows you how to manage functional limitation reporting for a patient with a prior unplanned discharge.
For Clinicient clients, our functional limitations wizard has reduced the complexity and confusion by walking you through the required steps and ensuring your clinical notes support the assessment. In a follow-on communication, we will address directly how our wizard will help you with this new wrinkle without making you pull your hair out. To learn more about our Functional Limitation Reporting capabilities, click here.
Please, feel free to email me directly with any questions. I will help you any way that I am able to manage your way through this. You should get paid what you deserve for Your Great Care.
As always, I am very interested in your comments and opinions below.
If your practice needs a better way to manage Functional Limitation Reporting that makes it easier for therapists, administrators and billing staff, schedule a demo to learn more about our all-in-one EMR and billing solution that helps practices manage patient to payment and get paid for what they’ve rightfully earned.
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