By Susan Rohde
May 23, 2017
In a world of ever-changing health care rules and regulations, the global surgical package has remained virtually unchanged--until recently. Under the current policy, the Centers for Medicare and Medicaid Services (CMS) has assigned a global period of 000, 010, or 090 to each surgical procedure listed in the Current Procedural Terminology (CPT) book. Generally speaking, all postoperative visits related to the procedure that take place within the global period are inclusive and typically not assigned a code.
In 2014, CMS began talks about transitioning all 010 day global procedural codes to 000 days in 2017 and all 090 day global procedural codes to 000 days in 2018. With this proposed rule, providers will now be able to assign and bill a code for all visits after the surgical procedure utilizing CPT code 99024 (postoperative follow-up visits).
CMS will start collecting data July 1, 2017. Reporting is only required for traditional fee-for-service Medicare patients when Medicare is the primary payer for the global procedure. Providers in the following nine states will assign CPT code 99024 (postoperative care) to all visits following 293 specific surgical procedures: Florida, Kentucky, Louisiana, Nevada, New Jersey, North Dakota, Ohio, Oregon and Rhode Island. This applies only to group practices containing 10 or more providers. CMS is encouraging providers that are not required to report to assign CPT code 99024 but they are not mandated. It should be noted that if an Evaluation and Management (E/M) code is being assigned in the postoperative period, for a reason unrelated to the surgical procedure, modifier -24 (E/M unrelated to surgical procedure) should be appended to the code and CPT code 99024 should not be assigned.
CMS has explained the change due to concerns that payment rates for global surgery packages are not updated on a regular basis and the relationship between the work relative value unit (RVU) and the number of included postoperative visits is not always clear. Also, the global package "assumes" the same provider that furnishes the procedure is also furnishing the postoperative care, meaning RVUs (how physicians are paid) may be left on the table for other physicians seeing the patient postoperatively.
When President Obama signed the Medicare Access and Children's Health Insurance Program Reauthorization Act of 2015 (MACRA), the legislation to change global periods to 000 days was banned. However, CMS is now required to collect data from a representative sample of providers. MACRA also allows 5 percent of surgical payments to be withheld until this data is reported, an incentive to get this done. In 2019, CMS will review all the data collected to identify the accuracy of the valuation of all surgical procedures.
While this seems like a major change, some organizations are lobbying against it. For instance the American College of Obstetrics and Gynecology (ACOG) has stated this new plan will have an annual cost of $95 million and necessitate the filing of more than 63 million additional claims. Patients will now be responsible for copays on each subsequent postoperative visits (they do not apply under the current system), which specialty groups fear will discourage patients from returning for their postoperative visits. There's also concern that CMS contractors will not be prepared to accept CPT code 99024. CMS states they are working with contractors to ensure that providers will be able to assign a 1-cent charge on the claim if providers' software requires a charge be on the claim.
CMS has dedicated the following email address to field any questions/concerns related to this new policy: firstname.lastname@example.org.