The Centers for Medicare & Medicaid Services (CMS) this month has begun collecting data on postoperative visits provided in the 10- and 90-day global period. CMS is collecting postoperative visit data in three ways: through claims-based data reporting; via a practitioner survey; and by direct observation of certain sites, including from accountable care organizations. This column focuses on the first component—claims-based data reporting.
Why does CMS require reporting of global codes data, and why should health care practitioners comply with this policy?
This mandatory policy is designed so that CMS can gather enough data on postoperative visits to improve the accuracy of global code values starting in 2019. If practitioners do not report, CMS will be unable to collect accurate and complete data, and reimbursements for 10- and 90-day global services could be negatively affected in the future.
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 successfully opposed this transition because it would have resulted in a reduction in surgeons’ reimbursement for 10- and 90-day global services.
The Medicare Access and CHIP (Children’s Health Insurance Program) Reauthorization Act (MACRA) of 2015 prevented the transition of all 10- and 90-day global codes to 0-day global codes but required CMS to collect data starting in 2017 to ensure the accuracy of the value for global codes 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; however, the agency had not implemented the withhold at press time.
Who needs to report postoperative data under this requirement?
Starting July 1, CMS now requires both physician and nonphysician health care practitioners in nine states to report data on the number of postoperative visits that they provide for select 10- and 90-day global surgical codes. Reporting is required for practitioners in groups of 10 or more located in Florida, Kentucky, Louisiana, Nevada, New Jersey, North Dakota, Ohio, Oregon, and Rhode Island. These practitioners are required to report American Medical Association Current Procedural 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. (Refer to the April issue of the Bulletin for a list of applicable codes.†) The data collected will be used to improve the accuracy of global codes starting in 2019. The American College of Surgeons (ACS) strongly urges all surgeons who are required to report to comply with this policy. Inaccurate and incomplete data collection may have a negative effect on 10- and 90-day global services.
How should practitioners report postoperative visits?
Postoperative visits should be reported through the usual process for filing claims. Practitioner, beneficiary, and date-of-service information should be submitted. The postoperative visit (the 99024 code) need not be linked to the related 10- or 90-day global code, and it is not necessary to add any modifiers. Practitioners should follow usual Medicare billing requirements to demonstrate that visits were provided and a code was correctly used (such as a chart note).
How does CMS define a “group” and how should practitioners determine whether they are in a group of 10 or more practitioners?
Both physicians and nonphysicians count for the purposes of determining whether a group comprises 10 or more health care practitioners. Unlike other Medicare programs, CMS does not define a group based on a shared tax identification number (TIN); rather, for these purposes, practices are defined as a group if their business or financial operations, clinical facilities, records, or personnel are shared by two or more practitioners (not necessarily at the same physical address).
Practitioner count should include all billing physicians and nonphysician practitioners regardless of whether they are furnishing services under an employment, partnership, or independent contractor model. For the purposes of this policy, CMS will look at whether practitioners share a facility or other resources.
What if a practitioner provides services in two practices, but only one meets the size threshold?
These practitioners are required to report under this policy. Practitioners are required to report if they have relationships with at least one group of 10 or more health care practitioners. Practitioners in this situation must report all eligible postoperative visits, no matter which practice is associated with the procedure.
How should practitioners account for part-time/short-term practitioners and staff fluctuation?
When practitioners provide services in multiple settings, the count may be adjusted to reflect the estimated proportion of time spent in the group practice and other settings. Generally, practitioners in short-term locum tenens arrangements should be omitted from the count of practitioners. Practices should determine their eligibility based on the typical number of practitioners who worked in the practice in the first six months of 2017.
What if postoperative care is transferred to another practitioner?
Reporting is required when a postoperative visit is furnished by another health care practitioner who is in the same practice or shares the same TIN. The practitioner who assumes responsibility for postoperative care should submit 99024 claims for postoperative visits if they meet other sampling requirements (that is, they practice in one of the nine selected states and their group includes 10 or more practitioners). This new reporting requirement does not change the services covered in the global payment period. If another practitioner in the TIN provides care that is unrelated to the procedure, the practitioner should continue to bill using the relevant evaluation and management (E/M) or other Healthcare Common Procedure Coding System (HCPCS) code.
What if a practitioner furnishes other services to the same patient on the same day?
All postoperative visits covered by the global period must be reported. If furnishing multiple postoperative visits to the same patient on the same day, only report 99024 once. Any service not covered by the global period is subject to normal billing rules.
Is reporting also required for Medicare Advantage and Veterans Affairs patients?
No. Reporting is only required for traditional fee-for-service Medicare patients and when Medicare is the primary payor for the global procedure.
Are CMS contractors prepared to accept 99024 claims? Can a small charge be attached to the claim?
CMS is working with contractors regarding appropriate processing. CMS also is working to enable its contractors to process claims for which providers put a 1 cent charge on the claim if the provider’s software requires some charge for submission.
I am a surgeon who is required to report. Where can I find more information?
*All specific references to CPT codes and descriptions are © 2016 American Medical Association. All rights reserved. CPT and CodeManager are registered trademarks of the American Medical Association.
†Ollapally V. Reporting global codes data in 2017. Bull Am Coll Surg. 2017;102(4):40-51.