On July 1, 2017, the Centers for Medicare and Medicaid Services (CMS) will begin requiring practitioners in nine states who are part of groups of 10 or more to report data on the services that they provide for select 10- and 90-day global surgical codes. The data collected will be used to improve the accuracy of global codes starting in 2019.
Which states are impacted by the requirement to report global codes data?
What data must be reported?
Health care practitioners who meet claims-based data collection requirements will be required to report American Medical Association Current Procedure Terminology (CPT)* code 99024, Postoperative follow-up visit, normally included in the surgical package, to indicate that an evaluation and management service was performed during a postoperative period for a reason(s) related to the original procedure, for every postoperative visit they provide within the global period of a select list of 10- or 90-day global codes. CMS selected 293 services, which are provided to Medicare patients by more than 100 practitioners per year and are either furnished more than 10,000 times or have allowed charges of more than $10 million annually. The agency estimates that these 293 codes describe approximately 87 percent of all furnished 10- and 90-day global services, and approximately 77 percent of all Medicare expenditures for 10- and 90-day global services under the physician fee schedule.
Is claims-based data reporting mandatory? Is there a penalty for failure to report?
Reporting is mandatory. CMS’ goal is to gather data on postoperative visits as part of its effort to improve the accuracy of global code values starting in 2019. CMS has the authority to implement a 5 percent withhold in payment for global services for health care professionals who fail to report but has not implemented the withhold at this time. Although there is no penalty or withhold of payment for failure to report, ACS urges all surgeons required to report data to comply. Failure to report will result in incomplete data and should data analysis of both inpatient and outpatient postsurgical visits not reflect existing global code definitions, new assumptions may be created to redefine postoperative care.
Why is CMS requiring the reporting of global codes data?
For several years, CMS has communicated its concerns about the accuracy of the values assigned to 10- and 90-day global codes. In 2014, CMS proposed to transition all 10- and 90-day global codes to 0-day, with the requirement that postoperative visits would be reported separately. The ACS argued against this transition because it would have resulted in a reduction in surgeons’ reimbursement for 10- and 90-day global services.
Dr. Bailey is a pediatric surgeon, and Medical Director, Advocacy, for the Division of Advocacy and Health Policy in the ACS offices in Washington, DC.