A much awaited Frequently Asked Questions – FAQ – document on Functional Limitation Reporting (FLR) was posted by CMS to provide clarifications to provider questions brought up during the 6 month testing phase which began on January 1, 2013. Providers that have already been reporting on patient functional limitations, via G codes and impairment modifiers, are relieved to find out that CMS will not require a hard restart on July 1st. If you have started reporting functional limitationsand have included the appropriate G codes and impairment modifiers on your claims, you will continue to report on patient status at the next reporting interval/progress report.
In the five page document CMS addressed 22 questions in several different categories to address 1) who is subject to reporting, 2) how to report functional functional information, assessment tools, and claims requirements. Most information provided by CMS provides information that has already been conveyed in the December 12, National Provider Call, updates by the various Medicare Administrative Contractors, and in the CMS transmittals and MedLearn Matters article. For those outpatient therapy providers that have participated in the testing period, the FAQ is likely to provide additional clarification on reporting of a second functional limitation, as well as clarification on therapy assistants documentation on the day that the second functional limitation reporting begins.
Heads Up on Documentation Requirments for Hospitals: Observation and Inpatient Part B!
Hospitals will face some incredible challenges with the reproting requirements for observation patients. The use of obsevation status by hospitals has increased due to increased denials by the MACs and the Recovery Auditors (RACs), and the resultant appeals decisions at the ALJ level to pay for Part B services where the Part A services have been denied, and the resulting Medicare Court of Appeals decision on this matter.
In light of numerous recent Medicare Appeals Council and ALJ decisions on a recurrent Medicare payment issue and in association with this Ruling, CMS is concurrently issuing a proposed rule, entitled “Medicare Program; Part B Billing in Hospitals” addressing the policy of billing under Medicare Part B following a denial of a Medicare Part A hospital inpatient claim by a Medicare review contractor for the reason that an inpatient admission was not reasonable and necessary under section 1862(a)(1)(A) of the Social Security Act (the Act).
Therapists treating patients in the emergency department or an in observation bed may not know at the time of therapy if the patient will be admitted, and infact, initial coding may be changed prior to the hopsital submitting the claim.
CMS has additionally clarified that all outpatient documentation requirments must be met when reporting on Part B observation patients, as well as inpatients who only have Part B benefits. Hospital therapists that are not familiar with outpatient Part B documentation requirements have to brush up in the next week. Of a more critical nature may be hospital therapists who are documenting in the EMR that is has not been adapted for compiance with Medicare outpatient documentation requirements.