Global Surgery Data Collection News

Re: Global Surgery Data Collection
Dear SVS Member:

We are writing to inform you that CMS has established a process for reporting postoperative encounters, inpatient and outpatient, during the surgical 10- or 90-day global period for a select number of procedure codes. The physician fee schedule (PFS) reimburses services based on all services rendered during the global period, inclusive of surgical procedures and all postoperative visits, as a single PFS payment. Currently, there are three categories of global periods: 0-day; 10-day and 90-day.

In the 2015 final rule, CMS published a concern regarding accurate valuation of 10- and 90-day global period, since an objective valuation of postoperative services has never been performed. This led CMS to recommend converting all 10- and 90-day global codes to 0-day global codes, essentially removing all the value for postoperative visits from the PFS reimbursement for all global services. The Medicare Access and CHIP Reauthorization act of 2015 (MACRA) prevented this policy from taking effect until a better valuation of services was developed.

After significant deliberation and discussions, CMS has finalized a claims-based data collection process to obtain an accurate number of postoperative visits provided within the global period. CMS will require that CPT code 99024 (postoperative follow-up visit normally included in the global surgical package) be reported via claims for all postoperative patient encounters, inpatient or outpatient, during the postoperative global period for select 10- and 90-day global codes. The surgical services identified for inclusion in this data collection (attachment enclosed) were screened by CMS as high value or high volume.

Mandatory reporting of 99024 for these procedures will start on July 1, 2017, however surgeons are encouraged to begin reporting as early as January 1, 2017. Of importance, only practitioners in nine states (Florida, Kentucky, Louisiana, Nevada, New Jersey, North Dakota, Ohio, Oregon, and Rhode Island) with practice groups of ten or more are required to report code 99024 on claims data forms for Medicare patients. This reporting will not encompass the level of care or time and resource utilized for each visit (ie, you will not be reporting visit level). Rather, it is designed to collect data about the number of patient encounters during the global period in order to assure that global procedure codes are correctly valued.

This initiative is of the utmost importance and non-participation in this mandatory data collection process will almost surely lead to reductions in reimbursement for physician services. In addition, CMS has the authority to implement a 5 percent withhold in payment for global services for those who fail to report, but the agency has not implemented the withhold at this time.

Failure to accurately report each inpatient and outpatient postoperative visit during the global period will lead to significant underestimation of the time and effort spent taking care of your patients. SVS recommends contacting your central billing office as well as your IT and electronic health system professionals to ensure accurate capture of all visits during the global period, especially during the inpatient hospitalization.

Additional resources can be found on the American College of Surgeons' website.

Sincerely,

Francesco Aiello, MD
Matthew Sideman, MD, Chair
SVS Coding Committee