I had reservations about the Functional Limitation G Codes and the Severity Modifiers as defined by Centers for Medicare and Medicaid Services (CMS).
I am all for quality and transparency around quality. I'm also for setting standards of care based on quality. What I don't appreciate: reporting functional limitation and severity modifiers that aren't standardized, valid or reliable. Everyone who participates with Medicare has been reporting this information. Future decisions will be made based on the data from what is reported.
CMS mandated something that will have ramifications for our profession. CMS views rehabilitation as a cost generator. I highly doubt that CMS will change its view because what was mandated isn't adequate for providing helpful information on the change that occurs with receiving rehabilitation services.
There is currently one published study indicating the short comings of CMS mandated functional reporting. For those of you using AM-PAC, I have bad news for you. Where the initial AM-PAC score falls within the correlated severity modifier has an impact on whether the patient will improve or decline. In other words, since the severity modifiers are not matched with the measurement tool and the tool's responsiveness to change, your patient's actual change is not being captured.
When mandates are not based on science or evidence, the results can be suboptimal. The results of this study irritate me. For those of us who have been doing the right thing and have been very conscientious about measuring and managing quality, we have a huge obstacle to overcome. CMS mandates something that is not adequate with regard to responsiveness to change.
I don't know the answer... and I don't know the track record of CMS admitting errors like this. This type of error will provide a foundation for future decisions: future decisions based on garbage.
Until next time,