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:
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!
Last summer’s Loper Bright decision was supposed to be a watershed moment for administrative law. By overturning Chevron deference, the U.S. Supreme Court declared that
EDITOR’S NOTE: This morning on Monitor Monday, senior healthcare analyst Frank Cohen related how he lost an extrapolation appeal because the Administrative Law Judge (AJL)
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