Breaking News: CMS proposes retiring FLR in 2019

Call me pleasantly stunned. In their annual Notice of Proposed Rulemaking (NPRM), CMS is proposing to retire the Functional Limitation Reporting requirement in 2019. So, after a five-year experiment, complete with bureaucratic bungling they have finally concluded the obvious: this was a burdensome, ill-conceived exercise in garbage data collection. 

Among the more interesting comments in the NPRM: 

  • “the functional reporting requirements for outpatient therapy services are overly complex and burdensome” (Uh, yes, we have known that for a long time.) 
  • “we reviewed and analyzed the data internally but did not find them particularly useful in considering how to reform payment for therapy services as an alternative to the therapy caps” (We knew you were collecting garbage data from the beginning.) 
  • “only 36 percent of the episodes reported discharge data” (Also a predictable problem.) 

Commenters on the request for information from CMS documented in the NPRM criticized CMA “for not having shared with them an analysis of the functional reporting data we had collected to date”. CMS explains that they were not required to share any such analysis. So, even though we all pay taxes and invested time and resources to collect this data, the attitude from CMS is “let them eat cake”. 

Feeling lost in a fog of MIPS terminology? Download our MIPS glossary to gain a better understanding of its common and not so common terms.

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So, the good news is truly good, and I applaud CMS for proposing to eliminate this program at long last. But, hard on the heels of this news is that PT and OT are likely going to be subject to the Merit Based Incentive Payment System (MIPS).   

We are studying the requirements carefully and will support our clients with MIPS participation like we have done with Functional Limitation Reporting and other Medicare requirements.  

Stay tuned, we will be offering webinars and other resources to help with the transition to MIPS. 

Disclaimer: The information provided herein is intended to be general in nature. It is not offered as legal or insurance related advice, and is not a complete description, or meant, or intended, to replace or be interpreted as specific, of Medicare requirements. Although every effort has been made to ensure the content herein is correct, we assume no responsibility for its accuracy. Contact Department of Health & Human Services (DHHS) Centers for Medicare and Medicaid (CMS) Services for more information.

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