FAQ: Functional Limitation Reporting

As of January 1, 2019, PTs, OTs, and SLPs are no longer required to complete Functional Limitation Reporting for Medicare Part B and Railroad Medicare beneficiaries. Commercial payers (e.g., Medicare Advantage plans or workers’ compensation plans) that adopted the FLR system are not affected by this change unless they individually decide to discontinue the program.

Medicare FLR

Do I need to complete Functional Limitation Reporting for Medicare patients?
No, as of January 1, 2019, all rehab therapists are no longer required to submit FLR g-codes or severity modifiers in when documenting Medicare Part B or Railroad Medicare participants.

Can I continue to complete FLR fields when documenting for Medicare patients?
No, as of January 2020, Medicare began denying claims with FLR G-codes.

Commercial FLR

Do most insurances require Functional Limitation Reporting? 
Clinics will only need to comply with Functional Limitation Reporting if they see patients with commercial payers (e.g., Medicare Advantage plans or workers’ compensation plans) that adopted the FLR system and have not decided to discontinue the program.

How will I know if my commercial insurance no longer requires FLR?
These payers will notify your practice directly if they are discontinuing functional limitation reporting. If you do not receive notice by January 1, 2019, continue submitting your FLR G-codes and severity modifiers. 

Does the corresponding modifier need to be in the documentation or just on the claim forms? 
You must document the G-codes and modifiers in your notes and on your claim forms. Selecting the Functional Limitation Reporting insurance setting for each payer that requires FLR will ensure that your documentation requires the use of G-codes and modifiers.

How many Outcome Measurement Tools do I need to include? 
For Functional Limitation Reporting, payers typically require at least one outcome tool. Essentially, how many you need to use to assess the functional limitation of your patients; that is up to you, as the PT. However, you must use functional limitation scoring as part of your assessment in determining your patient's severity impairment percentage and then report that to the payer (in the form of a G-code and a corresponding severity modifier).

Can I change my projected goal status mid-treatment? And how do I document that? 
Yes, you can change the patient's projected goal status in any evaluative note. You will need to clearly document why you're making the change and provide observations, measurements, and tests that decision. However, we do not recommend changing the projected goal status on the discharge note just because you didn't make the goal you wanted to make.

Do you need to complete functional limitation reporting for patients with a Medicare Replacement or Medicare Advantage plan? 
You do not need to complete FLR for patients with a Medicare Replacement or Medicare Advantage plan unless specifically instructed to by the payer.

How do I document a patient that does not fall into a specific Functional Limitation category? 
If you have a patient that you would like to treat but does not have an applicable functional limitation, you can select the Other checkbox in the Current Functional Limitation section and choose Therapy Services are not Intended to Treat a Functional Limitation. Then, select Other as the primary functional limitation. For example, if you have a patient that comes into your practice for e-stem, as prescribed by the physician, but you are not working towards a larger goal, this would be a good use of the Other primary limitation.