American College Of Surgeons - Inspiring Quality: Highest Standards, Better Outcomes

CMS Data Collection to Improve the Accuracy of Valuation for Global Codes


Update: Register Now for CMS Call on Global Codes Postoperative Care Data Reporting

The American College of Surgeons (ACS) encourages members who are subject to the Centers for Medicare & Medicaid Services (CMS) reporting  requirements for 10- and 90-day global services to participate in a CMS teleconference, 1:30−3:00 pm, Tuesday, April 25. This call will provide information about the new reporting requirements, along with reporting resources and tools. 

The rule takes effect July 1 and applies to practitioners who furnish 10- and 90-day global services on a CMS list of 293 codes and who practice with 10 or more other practitioners in one of selected nine states (Florida, Kentucky, Louisiana, Nevada, New Jersey, North Dakota, Ohio, Oregon and Rhode Island). These practitioners will be required to report Current Procedural Terminology (CPT) code 99024 for each postoperative visit related to the specified codes for services that they provide to a Medicare patient. 

The call will include a question-and-answer period. Coders, billers and practice managers in the nine states are encouraged to participate as well. Details about the call, including registration information, are posted on the CMS website.


Provisions in the 2017 Medicare Physician Fee Schedule: What Surgeons Need to Know

The Centers for Medicare and Medicaid Services (CMS) finalized a policy, required by the Medicare Access and CHIP Reauthorization Act (MACRA), whereby certain physicians who provide 10- and 90-day global services would be required to report information on the number of postoperative visits they provide.

Claims-Based Data Collection

Starting July 1, 2017, physicians who are part of practices with 10 or more practitioners and who live in one of nine specified states will be required to report one CPT code 99024 (Post-operative follow-up visit, normally included in the surgical package, to indicate that an evaluation and management service was performed during a post-operative period for a reason(s) related to the original procedure) for each postoperative evaluation and management visit they provide within the global period. This includes every facility visit (inpatient, outpatient, observation), the visit for discharge day management, and every office visit within the global period that is related to the procedure.

The nine states where physicians would be required to report global code postoperative visits were selected to represent those with a variety of “sizes” (measured by the number of Medicare beneficiaries per state) in all nine Census Bureau regions. These states are:

  • Florida
  • Kentucky
  • Louisiana
  • Nevada
  • New Jersey
  • North Dakota
  • Ohio
  • Oregon
  • Rhode Island

Physicians in the nine selected states are not required to report on all 10- and 90-day global codes; rather, CMS has published a list of 293 10- and 90-day global codes that are furnished by more than 100 practitioners and are either furnished more than 10,000 times or have allowed charges of more than $10 million annually. CMS estimates that these codes will describe approximately 87 percent of all furnished 10- and 90-day global services and about 77 percent of all Medicare expenditures for 10- and 90-day global services under the PFS. This is a mandatory reporting requirement intended to allow CMS to gather enough data on postoperative visits for the purpose of improving the accuracy of valuation of surgical services under the physician fee schedule s starting in 2019.

It is important for every surgeon practicing in a group of 10 or more practitioners in one of the nine states listed above to download the list of 293 codes and become familiar with the reporting requirements that will be mandatory for Medicare patients beginning July 1, 2017.

Additional Data Collection via Survey

In addition to the claims-based data collection, CMS also finalized a policy to conduct a survey of practitioners to gain information on post-operative activities to supplement the claims-based data collection described above. CMS has not finalized the design of the survey instrument, but intends to begin surveying in mid-2017. This survey could impact physicians in all states, not just the nine states selected for claims-based data reporting. CMS has also indicated that the agency plans to collect global code data from accountable care organizations (ACOs), but has not described how it plans to collect those data or when the ACO data collection will start.

ACS Advocacy

The final rule on global codes data collection is a result of aggressive American College of Surgeons (ACS) legislative and regulatory advocacy efforts. CMS released a drastically improved policy on collection of data, compared to the proposed rule policy, which would have been impracticable for surgeons, in part because it would have created an unreasonable reporting burden that was not aligned with clinical workflow.

ACS legislative and regulatory advocacy efforts included letters to the Hill, meetings with members of Congress, letters to CMS, calls and in-person meetings with CMS staff, town hall meetings with CMS, strategic meetings of the ACS Health Policy and Advocacy Group and the General Surgery Coding and Reimbursement Committee, and the formation of an ACS-led Globals Coalition.

Changes to the CY 2017 MPFS Proposed Rule

Provision

Proposed

Final

Start date

January 1, 2017

July 1, 2017

How data are reported

G-codes reported in 10-minute increments

Use 99024 to report number of post-op visits

What data are reported

Pre-service and post-op care on all 10- and 90-day global codes

Just post-op visits on only high volume or high expenditure 10- and 90-day global codes

Who reports the data

All physicians, regardless of practice size, who provide 10- and 90-day services in all states

Physicians who provide 10- and 90-day services who are:

  • In a practice of 10+ practitioners AND
  • In one of the identified nine states, comprising a representative sample, which was required by MACRA

Additional Resources

MACRA

H.R. 2, the Medicare Access and CHIP Reauthorization Act (MACRA) includes a provision to prohibit CMS from implementing the CMS policy that would have transitioned 10- and 90-day global codes to 0-day global codes. Instead, beginning no later than 2017, CMS will collect data on the number and level of visits furnished during the global period and, beginning in 2019, use this data to improve the accuracy of the valuation of surgical services.

The provision also allows 5 percent of the surgical payment to be withheld until information is reported at the end of the global period, and grants authority to discontinue the reporting requirement if sufficient information can be derived from QCDRs, surgical logs, EHRs or other sources.

H.R. 2 Global Surgical Packages Text

Medicare Physician Fee Schedule

CY 2017 MPFS Final Rule

ACS Comment Letter

CY 2017 MPFS ACS Comment Letter (see pages 6–19)

Bulletin Articles about Global Codes

Changes on the horizon for global services payment
Preparing for MACRA implementation

Global Surgery Data

CMS Webpage on Global Codes Data Collection

For further information, contact regulatory@facs.org.