The last time I wrote about the new CMS reporting requirements for outpatient rehabilitation services about to go into effect on Jan. 1, 2013, I referred to the issue as practicing in the code of ‘G.’ Now that the CMS screws become tightened, and practice change becomes reality, these reporting requirements take on new meaning as politicians, policymakers and bureaucrats await the data to provide much-needed answers to the question of “What value do these services actually provide and what should we pay for them?”
Starting on Jan. 1, 2013 all outpatient bills submitted for Medicare payment must include the therapists expected goals for care along with a valid measure of that goal.
Before you start complaining about how CMS has changed the game and now you must do so much more in order to get paid, understand these requirements have always been in place, but for the most part ignored by CMS. This is nothing new and I am sure that goal setting and valid measurement was a major part of your basic professional preparation. The only difference now is that somebody is making sure you do it.
So, this reporting requirement is an exercise to get providers to do something they were supposed to be doing all along? I guess that is meaningful. Therefore, if everyone gets in a habit of documenting goals and measuring to what degree they are achieved, we can start making sense of what is working in care delivery and what is not. Now that is big and meaningful.
I agree, to improve patient function and achieve rehabilitation goals is a meaningful use of electronic records and data. However, what happens if nobody uses the same measures? At last count there are more than 300 published measurement tools for functional improvement. If everyone uses a different measure, will the data be meaningful?
For example, measure of a patient’s ADL function has many choices; each has a different approach to measurement and quantification. The “apples to oranges” analogy has long been debated without much resolution. The CMS history of mandating a measure for the purpose of classifying patients by resource requirement has not provided the evidence to identify what works best for whom in rehabilitation. Practice and outcome variances remain after 10 plus years of standard IRF-PPS payment.
CMS is acutely aware of the issues but seems to believe that any data is better than no data. The introduction of G-code functional modifiers is a way to homogenize patient status by percent change between each measure’s minimal and maximal ranking of function. On a scale of one to 10 what do you think about this approach? Did I hear someone saying meaningless?
The conversion of functional measures to a common code to indicate percent of impairment has been put forth as the methodology to at least get the data flowing. These calculations are the responsibility of clinicians using the measure ( i.e. convert the measure’s, scale, range, ceiling and floor to a ratio-based comparison of zero to 100 and then figure which percentile comparison group that score (result) falls into and report the patient status with one of the seven related G-code functional modifiers (CH, CI, CJ, CK, CL, CM, CN)).
In case you’re having trouble with the math, Mediware has developed a calculator to ease the burden. A set of the most commonly used measurement tools has been put into a calculator and is available by title. If more measures are needed, email me and I will see they are included.
If I read the law correctly, each clinician is free to use any functional measure to calculate the G-code function modifier, including their professional judgment. Just provide the rationale used to determine the scoring methodology and the measurement procedures followed. CMS will look for this in the patient’s medical record with subsequent audits. Good luck with this approach to meaningful. In the meantime, dust off those textbooks on care plan, coordinated care and goal management. All of a sudden, they are again in vogue and required.