The Honorable Thomas Price, MD
Secretary
Department of Health & Human Services
200 Independence Avenue, SW
Washington, DC 20201
Seema Verma
Administrator
Centers for Medicare & Medicaid Services
Department of Health & Human Services
200 Independence Avenue, SW
Washington, DC 20201
Re: Collecting Data on Resources Used in Furnishing Global Services
Dear Secretary Price and Ms. Verma: On behalf of the 23 undersigned organizations of the surgical coalition, we write to express concern with the implementation of the Centers for Medicare & Medicaid (CMS) policy requiring data collection on global services as finalized in the calendar year (CY) 2017 Medicare Physician Fee Schedule (MPFS) Final Rule. Our organizations put the welfare of our surgical patients above all else, and we urge CMS to view policy changes through the lens of any potential impact on patients by focusing initially on the best care delivery models and then developing appropriate payment models to facilitate these care delivery models. We support policy changes that improve patient care and increase the accuracy of physician reimbursement, but CMS’ data collection policy on global codes currently lacks sufficient information on its implementation and has already posed a serious barrier to the collection of accurate data.