As part of CMS’s continued focus on health equity, Functional Status Assessments (COA-FS) are transitioning into the 2025 STAR ratings program. This shift underscores the importance of understanding and supporting the daily living needs of older adults, particularly those in underserved or at-risk populations. By identifying changes in mobility and independence, COA-FS plays a key role in addressing disparities, improving outcomes, and safeguarding health equity. Ensuring these assessments are completed helps provide more personalized, equitable care aligned with CMS quality goals. 
Here are some tips to complete the Functional Status Assessment in your practice:

Documentation:

Within the medical record, there must be documentation of two items:

1. A complete Functional Status Assessment
2. Date of service that the Functional Status Assessment was completed

For a Functional Status Assessment to be compliant, ONE of the following must be completed:

• Address Activities of Daily Living (ADLs) or at least five of the following: bathing, dressing, eating, transferring (i.e., in and out of bed), toileting, walking.
• Assess Instrumental Activities of Daily Living (IADLs) or at least four of the following: shopping for groceries, driving/using public transportation, using the telephone, cooking/preparing meals, housework, home repair, laundry, taking medications, handling finances. 
• Complete a standardized Functional Status Assessment tool like:
  • SF-36®
  • Assessment of Living Skills and Resources (ALSAR)
  • Barthel ADL Index Physical Self-Maintenance (ADLS) Scale©
  • Bayer ADL (B-ADL) Scale
  • Barthel Index©
  • Edmonton Frail Scale©
  • Extended ADL (EADL) Scale
  • Groningen Frailty Index
  • Independent Living Scale (ILS)
  • Katz Index of Independence in ADL©
  • Kenny Self-Care Evaluation
  • Klein-Bell ADL Scale
  • Kohlman Evaluation of Living Skills (KELS)
  • Lawton & Brody’s IADL scales©
  • Patient Reported Outcome Measurement Information System (PROMIS) Global or Physical Function Scales©

Important to note:

• Functional Status Assessments performed in the inpatient setting do not meet the required criteria.
• Evaluating the function of a single body part (e.g., lower back, shoulder) does not constitute a Functional Status Assessment.
• Assessing only one functional activity (e.g., walking or transferring) is not sufficient to meet criteria. 

Tip: Creating a ready-to-go template for Functional Status Assessments may help streamline completion and documentation.

Applicable CPT Codes:

CPT 99483: Functional Status Assessment

CPT-CAT-II 1170F: Functional Status Assessed