Following our outpatient therapy webinar on November 28, there were a lot of questions about how this program would be implemented. I contacted CMS and forwarded staff the entire list of questions I received throughout the webinar in hopes they can clarify for their webinar on Wednesday, Dec. 12. Registration for that webinar can be located at: CMS CBOR Open Door Forum.
Here are some of the areas of clarification expected to be announced this week:
- Composite Scores and Functional Areas: CMS will clarify that the therapist should use their judgement in selecting the impairment area and apply the composite score to that area instead of using the ‘other’ category as referenced in the Final Rule.
- Documentation: CMS will continue the policy allowing flexibility in exactly where in the documentation the G-codes and modifiers are placed. There will not be a specific requirement to put those codes in the problem list, assessment or goals sections of the documentation.
- The KX modifier does not need to be applied to the G-codes when exceeding the therapy cap (assuming there continues to be a therapy cap exception process in 2013).
- The CBOR program is completely independent from the PQRS and ONC-HIT certification, and built upon the already existing requirements for what needs to be included in therapy documentation. You can find that here: Pub. 100–02, Chapter 15, Section 220.3, Subsection C and D) http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c15.pdf
I also provided references and commentary to the 45+ questions received during the webinar. You can stillview the webinar recording and download the slides for free. I am sure there will be more to talk about after the CMS Open Door Forum on December 12th. Stay tuned…
P.S. Mediware’s outpatient rehabilitation solution will help you stay compliant with the new CBOR requirements.