Insights: Article

CMS Anticipates Eliminating Global Surgical Package

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: macra_global_surgery@cms.hhs.gov.

Latest Insights

September 21, 2018
Article
In the wake of hurricanes, devastating results have been experienced by communities and businesses throughout the Texas Gulf Coast, Caribbean, Florida and southeastern United States. As a result of these catastrophes, businesses will turn to…
September 20, 2018
Firm News
Eide Bailly LLP announced the winners of its 2018 Nonprofit Resourcefullness Awards, recognizing creative and sustainable revenue ideas from nonprofits in Arizona, Colorado, Minnesota, North Dakota and Utah.
September 19, 2018
Article
The IRS has started sending out Letter 5699 asking businesses to verify if they should have filed Forms 1094/1095-C. These forms are required for all ALEs.
September 19, 2018
Recorded Webinar
Are you considering doing business or having employees in Pennsylvania? Have you had issues with your state tax filing? Join our state and local tax team for some helpful insights into Pennsylvania tax filings.
September 19, 2018
Recorded Webinar
Are you considering doing business or having employees in Nevada? Have you had issues with your state tax filing? Join our state and local tax team for some helpful insights into North Dakota tax filings. This webinar will cover registration,…
September 19, 2018
Recorded Webinar
Are you considering doing business or having employees in North Dakota? Have you had issues with your state tax filing? Join our state and local tax team for some helpful insights into North Dakota tax filings. This webinar will cover registration,…
September 18, 2018
Article
As the largest tax reform legislation in the past 30 years becomes reality, it is important to stay up-to-date on planning opportunities and how reform may impact you and your business. Our Tax Reform: Practical Insights examples aim to break down…
September 18, 2018
Tool
Get ahead of tax season with the Eide Bailly Tax Planning Guide. A supplemental strategy guide to help guide year-end and make the tax laws work for you.
September 18, 2018
Article
The SCOTUS Wayfair decision has prompted a new focus on state and local tax compliance. The decision to register, report, and comply is important.