CMS Releases Functional Limitation Reporting FAQs

June 20, 2013
Rick Gawenda

On June 20, 2013, the Centers for Medicare & Medicaid Services released the long awaited FAQs on the new Medicare G Codes and mandated reporting of patient functional limitation that becomes mandated to report on July 1, 2013. The document contains 22 FAQs on topics including how to report functional limitations, use of assessment tools, and claim requirements. To access this member only benefit, click

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  1. If a patient attends PT on visit 1 and has multiple diagnoses, say a shoulder and a knee, and you pick which one to focus on as primary, do you still report 3 more codes to identify that you evaluated a secondary body part?

    1. If both evaluations were done on the same day, no. If you are a Gold Member, please check out Functional Limitation Reporting FAQs.

  2. Hi. Can you tell me if Medicare Advantage Plans are also requiring FLR in Ohio, specifically Humana? We have tried calling to get an answer but they are not clear. Thank you.

  3. I have a therapist asking me this and I do not know how to respond – she is quoting you…. I explained that Other is used like all the rest of the g-codes when there is not a functional limitation that matches the list..

    “Gwanda says that when you report Other Primary you do so with Current, projected and Discharge at the same time like you would an eval that you are not picking up treatments.
    I thought I saw somewhere else that you only use Current and Projected with the CH (0% ) modifier as you would any other eval.

    I ‘d like to verify the correct answer.

    1. Other primary is typically used for a wound care patient or possibly for a one-time only visit for an orthosis. If using the “Other Primary” category, this dos not mean it’s always a one-time only visit.

  4. Functional Limitation Reporting is due every 10 Tx days. Is it the same for progress reports then or are they still every 10 Tx days or 30 calendar days (whichever comes first)

  5. Good Morning
    Can you tell me anything about physical therapists as physician extenders? Are there billing considerations specific to this type of model? Thank you so much

  6. I am not sure if my reply went through so I am typing here.
    Are you aware of any circumstances when a PT may bill a treatment without billing an evaluation? Thank you so much!

    1. The question does not pertain to the topic of FLR FAQs. If you require consulting services, I do provide this and we can address your questions and different possible scenarios.