CMS Eliminates Reporting of Functional Limitation Codes

Original story posted on: February 13, 2019

  • Product Headline: Therapy Changes for 2019: Avoid Denials, Stay Compliant. Proceed with Extreme Caution
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CMS also has updated its therapy manuals, making elimination of FLR official.

Many therapy providers, at hospital outpatient departments and private-practice clinics alike, were reluctant to stop submitting functional limitation reporting codes and impairment modifiers until they could see the guidance clearly written in black and white in the associated therapy policy manuals. 

While the Centers for Medicare & Medicaid Services (CMS) had updated its therapy page with the good news about the elimination of functional limitation reporting, known as FLR, it seems that finding that page on the CMS website presented a challenge for therapists and billing managers looking for confirmation.

In news that did not disappoint, CMS recently released MLM Article MM11120, “Updates to Reflect Removal of Functional Reporting Requirements and Therapy Provisions of the Bipartisan Budget Act of 2018,” confirming what had already been confirmed via the CMS therapy page. The related change request, CR 11120, updates the following:

  • Chapter 12 of the Medicare Benefits Policy Manual: Comprehensive Outpatient Rehabilitation Facilities. Official Instructions Via R255BP.
  • Chapter 15 of the Medicare Benefits Policy Manual: Covered Medical & Other Health Services (Section 220-230). Official Instructions Via R255BP.
  • Chapter 5 of the Medicare Claims Processing Manual: Part B Outpatient Rehabilitation and CORF/OPT Services. Via R4214CP.

Through this MLM Matters article, CMS recapped the good news for the therapy industry, noting that “after a consideration of stakeholders’ requests for burden reduction and a review of the Middle Class Tax Relief and Jobs Creation Act of 2012 (MCTRJCA) requirements, (CMS) concluded in the CY 2019 MPFS final rule that continued collection of functional reporting data through the same format would not yield additional information to inform future analyses. The rule ended the functional reporting requirements to reduce the burden of reporting for providers of therapy services.” 

Good news indeed, as anyone one in the therapy industry will attest! Note to CMS: How about reducing the burden associated with the certification of the plan of care? Now that would be really good news!


Nancy J. Beckley, MB, MBA, CHC

Nancy Beckley is founder and president of Nancy Beckley & Associates LLC, providing compliance planning and outsourced compliance services to rehab providers in hospitals, rehab agencies, and private practices. Nancy is certified in healthcare compliance by the Healthcare Compliance Certification Board. She is on the board of the National Association of Rehabilitation Providers and Agencies. She previously served on the CMS Professional Expert Technical Panel for Comprehensive Outpatient Rehabilitation Facilities. Nancy is a familiar voice on Monitor Mondays, where she serves as a senior national correspondent.

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