2026 MIPS Measure #219: Functional Status Change for Patients with Lower Leg, Foot or Ankle Impairments

The American Physical Therapy Association (APTA), in their Guide to Physical Therapist Practice, described five recommended elements of patient management: examination, evaluation, diagnosis, prognosis and intervention. The elements were intended to direct therapists in their approach to patient treatment for the purpose of optimizing patient outcomes.

The APTA clearly identifies functional status data as one of the major forms of data to be collected for patients receiving rehabilitation. The functional status measures should be used to assist in the planning, implementation and modification of treatment interventions and should be used as measures of outcomes. The current functional status scores can be used by therapists to fulfill the recommended methods of the APTA in the management of patients in rehabilitation.

This measure contains one stratum defined by a single submission criteria. This measure produces a single performance rate. For purposes of MIPS implementation, this episode measure is submitted once for each treatment episode during the performance period. It requires submitting the patient’s FS PROM score, at a minimum, at the start (Initial Evaluation or Intake) and again at the conclusion (Discharge) of a Treatment Episode.

The Initial Evaluation score is recorded during the first treatment encounter, and the Discharge score is recorded at or near the conclusion of the final treatment encounter. Definitions: Functional Deficit – Limitation or impairment of physical abilities/function resulting in evaluation and inclusion in a treatment plan of care. Treatment Episode – A “Treatment Episode” is defined as beginning with an Initial Evaluation for a functional lower leg, foot or ankle deficit, progressing through treatment, without interruption (for example, a hospitalization or surgical intervention), and ending with Discharge signifying that the treatment has been completed.

A patient currently under clinical care for a foot, ankle or lower leg deficit remains in a single “Treatment Episode” until the Discharge is conducted and documented by the MIPS eligible clinician. Initial Evaluation – An “Initial Evaluation” is the first encounter for a functional deficit involving the lower leg, foot or ankle and includes an evaluation (CPT 97161, 97162, 97163, 97165, 97166, 97167, 99202, 99203, 99204, 99205, 99212, 99213, 99214, 99215, 98940, 98941, 98942, 98943*, 99304, 99305, or 99306), or an Initial Evaluation Status M-code (M1116).

A patient presenting with a lower leg, foot or ankle impairment, who has had an interruption of a Treatment Episode for the same functional lower leg, foot or ankle deficit secondary to an appropriate reason like hospitalization or surgical intervention, is an “Initial Evaluation”. Discharge – “Discharge” is accompanied by a treatment finalization and evaluation completion M-Code (M1011) identifying the close of a Treatment Episode for the same lower leg, foot or ankle deficit identified at the Initial Evaluation and documented by a “discharge” report by the MIPS eligible clinician.

An interruption in clinical care for an appropriate reason like hospitalization or surgical intervention requires a “discharge” from the current Treatment Episode. Encounter – A visit between the patient and the provider for the purpose of assessing and/or improving a functional deficit. Patient Reported – The patient directly provides answers to the FS PROM items .

If the patient cannot reliably respond independently (e.g. in the presence of cognitive deficits), a suitable proxy may provide answers. Risk Adjustment Factors – A set of factors used to calculate a patient’s risk score which predict the outcome score. In addition to the risk adjustment factors collected in the patient demographic portion of the assessment, a full list of considered specific comorbidity details can be found in Table 1 of this publication https://www.

ncbi.nlm.nih.gov/pubmed/29787696 1. LEPF PROM score 2 – The “LEPF PROM score” may be achieved using one of three forms: the FOTO LEPF PROM computer adaptive test, the FOTO LEPF PROM short form, or an alternative PROM score that is cross-walked to the FOTO LEPF PROM using a cross-walk form developed by the measure steward. Computer adaptive test (CAT) is recommended to achieve best balance between reduced patient burden and score precision.

At least one cross-walk form has been developed by the measure steward and meets scientific standards to successfully link a construct- equivalent PROM using advanced psychometric equating methods. For more information about the LEPF PROM score forms and to access the components that are available free of charge for use with this MIPS quality measure [e.

g., patient-reported outcome measure(s), cross-walking, risk adjustment], visit Public Access to FOTO Measures.