The January 1 – June 30, 2013 testing phase for functional limitation reporting is about to come to a close. Just when the therapy community was poised to transition in to the mandatory phase of functional limitation reporting (FLR) on Monday July 1st, CMS made a few statements in the Physician’s Open Door Forum (ODF) on June 4th suggesting that they were going to require a “hard” restart on FLR reporting on July 1st. In order to start the minimum 10 visit counter for claims submissions, CMS is likely to require that providers that have already been reporting FLR on claims submissions, will need to restart the clock for each Medicare beneficiary’s first visit on or after July 1st.
The therapy stakeholder group has been in regular communication with CMS regarding many therapy issues, including functional limitation reporting, but this apparently slipped through the cracks as rumors of the comments on the ODF reached APTA, AOTA, NARA, ASHA, NASL, AMRPA and other groups that have acted in unison on critical therapy issues. CMS has provided email confirmation to therapy stakeholders that have reached out for clarification on the matter, and they have confirmed thatthe CMS claims processing system will open a new therapy reporting episode and start counting to the next 10 treatment dates of service for claims on/after July 1, 2013 – meaning, of course, that providers have to begin their functional reporting again. CMS has indicated that additional clarification will be forthcoming in an upcoming MLN Matters Article.
Stay tuned for updates. If you are just getting started with FLR, you will likely enjoy a recording of an introductory webinar Last Chance: Learn Medicare Functional Limitation Reporting Basics with Clinicient.