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Author: Rick Gawenda

54 Comments

  1. Rick, regarding the Functional Limitation Reporting coming to the end – is that the functional G codes that we submit on eval and every 10th visit?

  2. Can Clarify the Functional limitations reporting for 2019?

    so we do NOT need to report for require med B and only supplemental medical insurance?

    • FLR is ending for traditional Medicare. You will have to check with Medicare Advantage plans and other insurance carriers to determine if they will continue with FLR.

  3. Hi Rick,
    We are a private practice that does not participate with Medicare or Medicaid, so will we be required to participate in MIPS, or not? Thank you

    • MIPS applies only to traditional Medicare Part B. If you do not participate with Medicare, then you can’t participate in MIPS.

  4. Hi Rick, thanks for the great info as always. can you tell me if they have finalized the rule to remove the Functioning reporting as of 1/1/19, or are we still waiting for confirmation. thanks Kim

  5. Are CAHs exempt from the PTA and COTA services payment reduction? I recall seeing that information somewhere but have not been able to locate it since. Thank you!

  6. Hi Rick- thanks for condensing this information for us. Trying to read through the final rule itself challenging! In regards to FLR: will you clarify what it means that “Medicare is finalizing their proposal to end FLR”. Does that mean that more details will be forthcoming?

    • In July, CMS proposed to end FLR effective January 1, 2019. In the final rule released on November 1, 2018, CMS finalized (confirmed) their proposal to end FLR. FLR for traditional Medicare Part patients is ending at the end of 2018.

    • Last date of service to report G-codes on a claim form for traditional Medicare Part B is December 31, 2018. No G-codes required after that.

  7. Great summary as usual Rick. Thank you.
    In the proposed rule, I believe the modifiers being suggested for use when the patient was treated by an assistant could be used on a voluntary basis beginning sometime in 2019, but would be required beginning with dates of service on and after January 1, 2020. Is this still a possible option for 2019?

  8. Hi Rick. Thank you for providing these valuable updates. If billing via a UB-04 form (hospital-based) for outpatient PT/OT/Speech, will issuance of an ABN be required in any situation given the Final Rule for 2019?

  9. Hi Rick, can you clarify a point about FLM reporting going away in Jan 2019? In the final rule it states that they are retaining the codes until CY 2020, is that so those who need to report for billing have time to switch over? We are transitioning to a new EHR next year and are trying to determine if we need to keep the G-codes for FLM. Thanks for your information!

    • FLR is no longer required for traditional Medicare Part B patients effective January 1, 2019. The FLR g-codes will still remain since they are tied to the 7 FOTO measures that are applicable to MIPS.

  10. Many of our commercial Medicare products (e.g. Medicare + Blue) have a standard line regarding therapy coverage: “follow medicare guidelines”. This was helpful as it indicated we were to follow therapy cap and FLR g-code requirements. Will that same phrase now mean no FLR g-codes required? Do you think they are that ‘in-step’ with Medicare?

    • Just because a Medicare Advantage (MA) plan stated they “follow Medicare guidelines” did not mean they had a therapy cap, required signed plans of care, required FLR, etc. In fact, most did not have a therapy cap, did not required signed plans of care and did not implement FLR. If a MA plan did implement FLR, you would have to check with them to see if FLR is going away in 2019 or not.

  11. Rick,
    Does the 2019 fee schedule apply to all those who bill for Part B therapy services? I get confused as to if this applies to CORFs and ORFs (rehab agencies) or only PT/OT/ST in private practice and Therapy group practice. Do all these “environments” get paid similarly? Any resources to look into this? Maybe I should restructure to be an ORF. Thanks.

    • The rates are the same for all outpatient therapy settings for Part B therapy services paid under the Medicare Physician Fee Schedule.

  12. Hi Rick- I wanted to confirm (as noted in 9/17 MIPS article) there is no change and if you bill on a UB-04 you are not eligible to participate in MIPS? Thank you!

    • MIPS applies to private practices. You know if you are a private practice under the Medicare program because you submit your claims on a 1500-clai form.

  13. Rick was there any mention if payment would be made for the cognitive code 97127, or would we still need to use the G0515 code?
    thanks!

  14. Hi Rick.
    Thanks for answering my last question. Also wanted to ask, Do we report MIPS quality measures just at evaluation and re-certification? Thanks.

  15. Rick,
    Just thought of another question. With the new therapy modifiers for PTAs and COTAs, will we start reporting those in 2019 or not until the rate reduction comes into play in 2022? Thanks again.

  16. We bill on the UB-04 form so are not eligible to participate in MIPS but does that mean we will be subject to payment reductions since we are not participating in the MIPS program

    • The payment adjustments, both positive and negative, only apply to MIPS eligible clinicians. Since you are not eligible, the payment adjustments will not apply to you.

  17. Rick, have you seen the final rule regarding FLR or have an estimate release date for the final rule? In this rule, it only says CMS is finalizing their final rule. As an institutional biller, we cannot discontinue the FLR’s until we have that final ruling in hand from CMS. Thanks for the help.

  18. With Functional Limitation Reporting no longer required for 2019, is there any requirements or guidelines on having to complete discharge FLR on the final date of service for 2018 or are we able to just stop completing the reporting moving forward as of 1/1/2019? Thanks as always for you assistance and guidance.

  19. Rick, I know you have received many questions. I will make this brief. When G codes FLR was in place and patient wanted to stop treating for one body part and start treating for another, we had to discharge with the proper dc g codes and then eval the new issue. Now that g codes are going away, do we still need to have patient officially dc before evaluating the new issue? Thank you. Lori F

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