Communication to the Centers for Medicare and Medicaid Services (CMS) from ASHA, speech-language pathologists, and other therapy organizations and therapists resulted in a change in the implementation of the functional outcomes reporting (G-codes) that begins July 1, 2013. In correspondence to ASHA, CMS offered the following guidance.
- Therapy providers who have been submitting functional reporting data during the testing period will not need to restart reporting on the first date of service (DOS) on or after July 1, 2013, for episodes of care for which functional reporting began during the testing period. In other words, for those episodes of care for which the therapist included G-codes on the claims for DOS prior to July 1, 2013, reporting after July 1, 2013, is required at the next regularly scheduled reporting.
- For beneficiaries whose treatment began prior to July 1, 2013, but for whom functional reporting information has not been submitted, the first claim submitted with a DOS on or after July 1, 2013, should be treated as the initial claim and must include the required G-codes.
Speech-language pathologists offering services to Medicare beneficiaries as outpatients (including patients seen in the emergency room and those under observation) must include G-codes on therapy claims beginning July 1, or claims for those services will be returned unpaid.
CMS will post Frequently Asked Questions for functional outcomes reporting for therapy services. FAQs are expected to provide additional guidance for
- reporting and documentation requirements for patients in observation status or seen in the emergency room for evaluations,
- patients seen for multiple evaluations when an evaluation is performed unrelated to the condition being reported,
- documentation and progress note requirements-progress notes are required every 10th treatment day, not 30th calendar day as required prior to 2013,
- reporting and documentation requirements for Medicare as a secondary payer.
Also on July 1, 2013, the reconfigured National Outcomes Measurement System (NOMS) will be available for NOMS users. ASHA members interested in using NOMS to track outcomes of their patients and to assist with code and modifier selection and documentation should register online.
Outcomes reporting on the claim form was mandated in the Middle Class Tax Relief and Jobs Creation Act. Congress required that CMS develop an outcomes reporting mechanism on the claim form for all outpatient therapy services. CMS developed a functional outcomes reporting process, which includes non-payable G-codes and severity modifiers, with a transition period from January 1-June 30, 2013, and full implementation on July 1, 2013. Anyone providing therapy, including speech-language evaluation and treatment services, for Medicare Part B beneficiaries must report outcomes on the claim form in this mandatory data collection program or claims will be returned unpaid for services rendered on or after July 1, 2013.
ASHA has compiled several resources to assist speech-language pathologists with the documentation and reporting requirements. All resources incorporate the information provided by CMS.
For more information on the claims-based outcomes reporting requirement, contact the health care economics and advocacy team at [email protected].