Functional Code Reporting Update from CMS

June 18, 2013 -  CMS has provided the following update based on the June 4th Open Door Forum statement that "on July 1st funcational reporting will start which requests doing initial evals, goals & status.  The July 1st treatment has to be treated as the initial eval, even if [provider] have been treating the patient.  [CMS] realizes it is 'a little bit of a burden' but feel it is necessary."   CMS had previously indicated that therapists must report functional information on the first claim with a date of service (DOS) on or after July 1, 2013, including claims for episodes of care for which Functional Reporting had begun during the testing period.  After hearing from many therapists and other stakeholders, we reassessed and are clarifying our reporting requirements effective for DOS on or after July 1, 2013.  Therapy providers who have been submitting Functional Reporting data during the testing period will not need to restart Functional Reporting on the first DOS on or after July 1, 2013 for episodes of care for which Functional Reporting began during the testing period.  In other words, for those episodes of care, for which the therapist included Functional Reporting on the claims for DOS prior to July 1, 2013, reporting after July 1, 2013 is required at the next regularly scheduled reporting.  For beneficiaries whose treatment began prior to July 1, 2013 but for whom Functional Reporting information has not been submitted, the first claim submitted with a DOS on or after July 1, 2013 should be treated as the initial claim and include the required Functional Reporting.