Generic filters
Exact matches only
Search in title
Search in content
Search in excerpt


Reader Interactions


  1. Mike Nichting says

    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. Lynn Stier says

    Can Clarify the Functional limitations reporting for 2019?

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

    • Rick Gawenda says

      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. Tom Bednar says

    For practices over 15 eligible providers ( PT, OT and ST) will they be able to report the MIPS data via claims?

  4. Suzanne Chase says

    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

    • Rick Gawenda says

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

  5. Kim Palma says

    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

  6. Rachel Judisch says

    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!

  7. Jeanne Bradshaw says

    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?

    • Rick Gawenda says

      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.

  8. Micchelle Morgan says

    Rick, Thanks for your expertise. Will Functional Level reporting be required to close out the ones opened in 2018?

    • Rick Gawenda says

      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.

  9. Bernadette Gapinski says

    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?

  10. David Lundgren says

    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?

  11. Ana Lotshaw says

    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!

    • Rick Gawenda says

      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.

  12. Cathy Metz says

    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?

    • Rick Gawenda says

      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.

  13. Jim Milani says

    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.

    • Rick Gawenda says

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

  14. James Riley says

    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!

    • Rick Gawenda says

      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.

  15. Jeanne Bradshaw says

    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?

  16. Jacob Gleason says


    So individual providers need to exceed $97K to qualify for MIPS? This is what I am hearing from my EMR system.

  17. Jim Milani says

    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.

  18. Jim Milani says

    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.

  19. Shon M Horan says

    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

    • Rick Gawenda says

      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.

  20. Julie White says

    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.

    • Rick Gawenda says

      Finalizing means they finalized what they proposed. FLR ends for traditional Medicare at the end of this year.

  21. Brian Soignier says

    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.


    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

    • Rick Gawenda says

      For 2018, you follow the FLR as they have always been. In 2019, FLR is no longer required for traditional Medicare.

Leave a Reply

Your email address will not be published. Required fields are marked *

This site uses Akismet to reduce spam. Learn how your comment data is processed.