Demystifying Medicare Functional Limitation G Codes

Assigning Severity Modifiers


The final July 1 deadline for reporting Functional Limitation Ratings is fast approaching. I have already expressed my opinion in prior blog articles about the flaws in this requirement, but that does not really matter much, since it is the law of the land.
This past week, we released a set of features in Insight that make the process for including Functional Reporting Classifications and Severity Modifiers on your documentation and claims easy to do.  As July 1 approaches, and this testing phase ends, we are monitoring claims remarks to make sure that claims for your Medicare patients will not be rejected. That is the easy part.

More difficult is assigning a meaningful impairment rating to your patients.  So I have been focusing my efforts to see how we can make complying with this process easier for Clinicient users. 

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I have reviewed transmittals, articles, slide presentations and transcripts from CMS, and similar resources from the APTA to learn more about these requirements and guidelines so I can give our users practical information on assigning impairment ratings.

While I have found reams of information on the mechanics of submitting the Functional Classifications and Impairment Ratings on claims and including that information on your clinical documentation; there is very little practical information on assigning an Impairment Rating for your patients in your clinical documentation.

Presentations from the APTA and from CMS[i] both recommend using widely accepted “Functional Assessment Tools” to determine a current impairment rating. Two of the key slides from the CMS presentationfrom National Provider Call December 12, 2012 presented by Pamela R. West, DPT, MPH are included here.

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The APTA has published an article on translating OPTIMAL[ii] scores to the Medicare Impairment Ratings.[iii]  Others have offered conversion tables or calculators to mathematically convert widely accepted Functional Assessment Tools into Medicare Impairment Ratings.[iv]

Mathematically converting common Functional Assessment Tool Scores to Impairment Ratings is relatively easy, and the information from CMS and the APTA seems to indicate that this method may be used to at least get you “in the ball park” to establish an impairment rating.

For your convenience, we have created some of the common Functional Assessment Tool Scores that are already converted to Impairment Ratings for your use:

  • Oswestry Modified for Medicare Impairment Ratings
  • Neck Disability Index Modified for Medicare Impairment Ratings
  • Shoulder Pain and Disability Index Modified for Medicare Impairment Ratings
  • Lysholm Scale Modified for Medicare Impairment Ratings
  • Lower Extremity Functional Scale Modified for Medicare Impairment Ratings
  • DASH Score Modified for Medicare Impairment Ratings
  • Quick DASH Modified for Medicare Impairment Ratings
  • Upper Extremity Functional Scale Modified for Medicare Impairment Ratings

Please email me if you would like these modified Functional Assessment Tools exported to your database, or if you have another widely accepted tool that you would like converted for Medicare Impairments. We would be happy to look at those instruments and modify them for you.

As we gain more guidance about the use of these tools, we will continue to share that information with you.

[i] Preparing for Therapy Required Functional Reporting Implementation in CY 2013; National Provider Call December 12, 2012. Presented by: Pamela R. West, DPT, MPH Centers for Medicare &
Medicaid Services, Center for Medicare Hospital and Ambulatory Payment Group,
Division of Practitioner Services.

Excerpt from Transcript explaining Slide 12:

“…you would use the severity modifier that reflects the score from a functional or outcome assessment tool or other performance measurement instrument as appropriate. In cases where the therapist uses multiple assessment tools or measurements tool during the evaluative process to inform clinical decision-making, clinical judgment is used to combine these results to determine a functional limitation percentage. And the third bullet, the therapist can use their clinical judgment in the assignment of an appropriate modifier. Therapists will need to document in the medical record how they made this modifier selection so that the same process can be followed at succeeding assessment intervals.”


[ii] Copyright © 2012, 2006,
2005 American Physical Therapy Association. All rights reserved.

[iv] Claims Based Outcomes Reporting Calculator. Mediware Information Systems.



Complimentary Webinar:

View a complimentary webinar with physical therapist Jerry Henderson and Keddrick Stuart.

Jerry provides therapists with an overview of functional limitation requirements, what is required of  therapists and when, and provides case studies of exactly how to use g-codes and severity modifiers according to functional limitations and treatment goals. A short demonstration is also provided to illustrate how the codes carry through on claim creation and eliminate billing risks that could increase audit risks.



Other Tools to Help:

Download G-Code Cheat SheetClinicient has created a G-Code cheat sheet for Functional Limitation Reporting. Click here to download your free copy.

If you are interested in learning more about how clinicient can help your practice reduce it’s risk with these new requirements, we encourage you to contact us to learn more.


Read all Functional Limitation Reporting blog posts


  1. Posted May 10, 2013 at 2:39 pm | Permalink

    Jerry – The industry seems to be divided among those that are aware of the reporting requirements and are in some level of preparedness, and those that don’t know this requirement. (YES, indeed, based upon quesions in the MAC webinars, as well as calls I am receiving – some are just now “finding out”). Of the therapists who know and are prepared, there is now a debate ensuing on the efficacy of this process, is impairment equal to disability, and do the “crosswalks” really create an impairment score?

    It will be interesting to see how CMS, and more importantly MedPAC begin looking at this data and interpreting the data. I think the researchers in the industry, such as Allan Jette PT, PhD (AM-PAC) and the folks are FOTO should serve as leaders to us NOW rather than later, when the data is ultimately interpreted, and the therapy industry inevitably does not like the findings.

    • Posted May 10, 2013 at 8:49 pm | Permalink

      Thanks, as always, Nancy. It will be interesting to watch this all unfold. As you know, I have really struggled rationalizing all of this. I have sent an email to Pamela West at CMS, asking for clarification on use of converted Functional Assessment Tool Scores, but I have not heard back from her yet.

      I will share her feedback with everyone as soon as I receive it.

  2. Julie Wong, PT, CLT
    Posted June 11, 2013 at 10:24 pm | Permalink

    Jerry, thank you SO much for the informative webinar today on G codes. It clarified a lot on how to implement them; especially with the forms that are used for the functional limitations. In the past, I have read about functional lilmitations and most of the articles state that one must use an acceptable questionnaire; but never specifying which ones! How am I supposed to know if I haven’t used them in the past??? You have really cleared things up and I am very grateful to you for sharing the information. Julie Wong, PT, CLT San Francisco

    • Jerry Henderson
      Posted June 12, 2013 at 5:17 am | Permalink

      Great, Julie, really glad you could attend and especially glad you found it helpful. We are really concerned about how this whole program will affect everyone.



  3. Ricardo Tubino
    Posted June 13, 2013 at 4:11 pm | Permalink

    Hi Jerry, Thanks for this blog! Thanks Clinicient staff for the great support to PTs! I am a physical therapist based in south florida, and I’ve been “pushing” the owner of my clinic to get your software!! Hopefully they will do it soon.
    Jerry, you mentioned that you cold send us the Functional Assessment tools, would you help me with that?

    One more time, thank you for all the support and continue with the great work!

    • Posted November 12, 2013 at 2:19 pm | Permalink

      Ricardo, I am so sorry I didn’t reply to this sooner. I was just bookmarking this article for someone else, and just now saw your comment.

      Thanks very much for your kind words. Hope everything is going well for you with all of these changes.


  4. Anna
    Posted March 29, 2014 at 4:51 pm | Permalink

    I have a question . if you report on first visit G codes , patient is coming 5 times only and stop coming and Coming in later for a month and have new diagnosis. what should we do with last 5 visit in past ? how to report that? if the patient stop coming

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