Every holiday season is a blur for me because it coincides with the annual end of year “scramble to support new CMS policies” event. But this year really takes the cake. With the dust barely settled on the phasing of Manual Medical Review and my head still spinning from the recent Medpac recommendations, it is already time to turn my attention to the new claims based data-collection strategy, popularly known as the new G-Codes.
Before we describe G-Codes in any way, let me address our community’s anxiety by stating Clinicient is tailor made to support this kind of integrated reporting. We will make this as easy for the therapist as possible. In essence, therapists are being asked to report a functional limitation and assign a percentage of impairment at specific points within the episode of care. This has to be translated into a set of G-Codes that can be submitted by claim.
You can expect Clinicient will automatically track the CMS requirements, prompt the therapist at the moment of documentation when reporting is needed, provide the therapist a simple pick list to record the information, and automatically include the appropriate G-code and modifier in the claim without any other intervention. As complicated as the rule is, this can be made simple with the right system.
What are the G-Codes and why do they exist?
As part of the Middle Class Tax Relief Act of 2012, CMS committed to collect data on beneficiaries’ functional outcomes from therapy services provided. This five (5) year project is intended to support payment reform with outcome based data. This is strictly a data collection effort and no other uses beyond analysis have been published.
To collect the data, CMS is using the most convenient collection method at hand, namely claim submission. Therapists are required to report Functional Limitations through a series of G-Codes (Gxxx8) and Modifiers (CX) at the outset of treatment, at least every 10 visits thereafter, and at discharge.
The G-Codes and modifiers must be present in both the medical record and the claim. In particular, the medical record is supposed to show what tools and other information led to the values submitted on the claim form.
Who has to submit them?
All practice settings that provide outpatient therapy services billing under Medicare Part B must include this information on the claim form. Specifically, the policy will apply to physical therapy, occupational therapy, and speech therapy services furnished in hospitals, Critical Access Hospitals (CAH’s), Skilled Nursing Facilities (SNF’s), Comprehensive Outpatient Rehabilitation Facilities (CORFs), rehabilitation agencies, home health agencies (when the beneficiary is not under a home health plan of care), and in private offices of therapists, physicians and nonphysician practitioners.
When do I have to start submitting?
CMS has directed the Medicare Administrative Contractors (MACs) to begin accepting G-Codes on January 1, 2013, but January 1stthrough June 30th is really an extended testing period. Beginning July 1, 2013 any claim without the G-Code functional limitation data will be denied.