Washington Update for May: SVS Seeks to Delay July 1 Data Collection Start Date

May 22, 2017 Re-posted from the May 2017 issue of Vascular Specialist

[[{"type":"media","view_mode":"media_large","fid":"1312","attributes":{"alt":"","class":"media-image","style":"width: 250px; height: 188px; float: right; border-width: 2px; border-style: solid; margin: 2px;","typeof":"foaf:Image"}}]]Though collecting data on post-operative services is to begin July 1, the Society for Vascular Surgery (SVS) believes the deadline should be delayed until several questions can be answered and education provided by the Centers for Medicare & Medicaid Services (CMS).

The SVS supported Congressional efforts to prohibit the elimination of the 10- and 90-day Global Surgical Packages included in the Medicare Access and CHIP Reauthorization Act (MACRA) enacted in 2015. The SVS also supported collection of data on post-operative services from a representative sample of physicians, a section included in MACRA.

In the 2017 Medicare Physician Fee Schedule Final Rule, CMS agreed with SVS to delay the requirements from Jan. 1 to July 1, 2017, for reporting claims-based data on post-operative services. CMS also agreed to use CPT code 99024, Global Post-Operative Visits to collect data. Reporting is limited to groups of 10 or more practitioners in the following states: Florida, Kentucky, Louisiana, Nevada, New Jersey, North Dakota, Ohio, Oregon and Rhode Island. In addition, the agency agreed to use only post-operative codes with high-allowed charges and high volume and not withhold 5 percent of Medicare services’ payments for not reporting information.

In April, the SVS signed onto a letter to CMS with other surgical societies (vsweb.org/GlobalCodesLetter) that requests clarification regarding claims-based reporting of post-operative data, including the following:

  • Defining the term "practitioner" for groups of 10
  • Why a "group" is defined not as practitioners sharing the same tax ID number as in all other cases of CMS reporting, but as those who share business or financial operations, clinical facilities, records or personnel
  • Whether practitioners will be able to submit claims for 99024 for post-operative visits from any site of service
  • If all CMS contractors are prepared to accept 99024
  • If two 99024 codes should be submitted if a practitioner sees a patient twice in one day
  • How CMS will handle the data from practitioners who do not consistently report 99024

The SVS doubts that CMS will be able to collect accurate and complete data that will be appropriate for improving the accuracy of global codes. Given the implementation hurdles and the quickly approaching start date, the SVS believes that it would be inappropriate to begin the collection of data unless CMS has addressed the above issues and provided adequate time for provider education.

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