CMS has clarified in an email to APTA that beginning July 1, 2013 “…therapy providers who have submitted functional limitation data (G-codes) on Medicare Part B patients prior to July 1 will not need to restart functional limitation reporting on the first date of service on or after July 1.” For these patients only providers are able to submit functional limitation data at the next required reporting interval. However for patients where functional limitation reporting has not started, CMS will still require functional limitation G-codes and modifiers on the first visit on or after July 1, 2013. For all new patients on or after July 1st, functional limitation reporting is Mandatory. CMS has indicated they will issue an FAQ or MedLearn Matters article prior to July 1st.
As noted in the previous post Functional Limitation Reporting – Time to Start – or Restart – July 1, 2013 CMS was considering a “hard” restart for the mandatory reporting of funcational limitations beginning on the first therapy date of service on July 1st or after. This left the therapy community and the therapy stakeholder group representing therapy organizations to contact CMS regarding the unnecessary administrative burden for claims systems modification, and therapy documentation modification, for those providers who have been using the January 1 – June 30th “testing” period to ensure that claims transmission with the G codes and modifiers were able to be billed and accepted by their Medicare Administrative Contractors. During this time many providers were also dealing with updates and modifications to their EMR, as well as internal claims processing work flow.
During the testing phase providers were also tuning up documentation to ensure that functional limitation reporting was consistent with fuctional long term goal(s) and that the therapist judgement and rationale for selection of impairment modifier were incorporated into all documentation elements including plan of care and progress reports.