Since July 2013, CMS has required PTs to complete functional limitation reporting (FLR) to receive reimbursement for your services. There were several glitches following the rollout, including a flurry of rejections in October 2013 and January 2014. Things have gone fairly smoothly since then, but there are still a few issues cropping up here and there. Let’s take a look at each one and how to handle it, keeping in mind that some private insurers now also require FLR.

1. Single plan of care, multiple diagnoses. If a therapist is treating a patient under a single plan of care and that patient later presents a referral from the same physician for a second diagnosis, the therapist should perform an evaluation to collect information on the new diagnosis and report functional limitation data on whichever condition is the primary one.

2. Multiple plans of care. If a patient is receiving treatment from two disciplines in your practice, each therapist should report the patient’s primary functional limitation under his/her plan of care. If a patient is receiving treatment within the same discipline, the first therapist identifies the patient’s primary functional limitation and reports it, and the second therapist completes functional limitation reporting as though he/she were performing a one-time visit on the date of evaluation for the second plan of care.

3. Patient self-discharges, returns after 60 or more days. If a patient stops attending therapy, Medicare considers the patient discharged 60 days after the last service date. If the patient returns to therapy, you do not have to complete discharge FLR for the original primary functional limitation. Simply perform a new initial exam and proceed with FLR as though you are treating a new patient.

4. Patient self-discharges, returns within 60 days. If a patient stops attending but returns within 60 days for the same functional limitation, you can just resume treating and documenting FLR as though he/she had not left.

5. Patient self-discharges, returns with 60 days for different functional limitation. In this case, you must complete discharge FLR for the patient’s original functional limitation during his/her first visit back.

There’s one last scenario that’s a bit more complex: a patient you are treating presents with a second diagnosis that’s unrelated to the original. In this case, you have three choices:

• Combine the issues into a single case (involves determining which diagnosis is the patient’s true primary functional limitation)
• Treat the cases separately on separate days (choose one case to be the reporting case)
• You and another therapist treat the cases separately (one therapist submits FLR data as normal; the other submits discharge FLR data and starts FLR for the new diagnosis on the next date of service)

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Last Updated on November 22, 2021