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Functional Limitation Reporting Requirements – Update from CMS

July 31, 2013 0 Comments

dog reading bookCMS issued a MLN Matters Special Edition Article SE1307 to update functional limitation reporting requirements.  The issues date is 7/30/2013, the effective date is 7/2/2013.  Clarification was issued in the following areas (from the article):

  • A reporting episode links a beneficiary to a specific therapy billing provier NPI.  In order to track beneficiary functional limitations, FLR reporting date is reproted per beneficiary, per therapy discipline and pre billing NPI on specified therapy claims for certain DOS.
  • Once one functional limitation is discharged and further therapy is medicallly necessary, reporting of the subsequent functional limitation begins on the next treatment day.
  • A reporting episode will automatically be discharged when it has been 60 or more calendar days since the last recorded DOC.

Additional guidance was provided for discharge reporting wherein the patient returns to therapy within 60 days after previously discontinuing therapy without notice.  Three unique functional reporting scenarios were described including:

  • One time therapy visit
  • Reporting evaluative procedures for mutliple POCs for the same therapy discipline
  • Therapy services from more than one therapy discipline on the same treatment DOS

It is likely that as CMS continues to receive functional limitation reporting data that further updates and clarification with be forthcoming.  It should be noted that hospitals data for July will not be submitted until early August, and given the special circumstances in hospitals (observations patients, Part B only inpatients) that further clarification will be essential.

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Nancy Beckley

Nancy J. Beckley MS, MBA, CHC: President-Nancy Beckley & Associates LLC. Compliance outsourcing, risk assessment, compliance plans, compliance training, auditing, due diligence, investigation support for therapy providers.

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