Global Surgery Data Reporting Requirements
AAO-HNS Advocacy Efforts (updated October 2017)
The CY 2017 Medicare Physician Fee Schedule Final Rule directed the Centers for Medicare and Medicaid Services (CMS) to collect data on post-operative visits for 10- and 90-day global services. CMS is moving on three fronts:
- Claims-based analysis starting July 1;
- Observational study; and
- Survey of physicians for information on post-operative visits. UPDATE: SEE BELOW
Claims-Based Data Collection
Starting July 1, 2017, select practitioners are required to report on post-operative visits furnished during a global period using CPT code 99024.
Which procedures are clinicians required to report 99024?
CMS selected 293 procedures which were furnished by more than 100 practitioners and were performed 10,000 times or have charges exceeding $10 million in 2014.
A full list of the 293 procedures can be found on the CMS global surgery data collection webpage. CMS will update the list of procedures subject to reporting annually through the rulemaking process.
Who is required to report?
Billing practitioners (both physicians and non-physician practitioners, including those working under physician supervision) are required to report post-operative visits if they:
- Practice in one of nine states (Florida, Kentucky, Louisiana, Nevada, New Jersey, North Dakota, Ohio, Oregon, Rhode Island); AND
- Practice in a group of ten or more practitioners; AND
- Are part of a practice that provides global services under one of the required procedure codes.
CMS defines a group as an entity whose business or financial operations, clinical facilities, records, or personnel are shared by two or more practitioners. They do not necessarily have to be in the same physical address.
How to report post-operative visits
Select practitioners are required to report post-operative visits for selected procedures furnished on or after July 1, 2017 using CPT 99024. Claims using 99204 do not need to be linked to the procedure, and time units or modifiers are not required to report 99024.
Post-operative visits will be reported through the usual process for filing claims including following usual Medicare billing requirements to demonstrate visits were provided and code was correctly used (such as chart note).
Additional Data Collection Via Survey
In addition to the claims-based data collection, CMS also finalized a policy to conduct a survey of practitioners to gain information on post-operative activities to supplement the claims-based data collection described above. This survey could impact physicians in all states, not just the nine states selected for claims-based data reporting.
The CMS contractor, RAND Corporation (RAND), reached out to the Academy for input on the development of the physician survey.
As a follow-up to the July 2017 article in The Bulletin, the Academy engaged in the advocacy efforts noted below, on behalf of members, that focus on reducing physician burden.
- The AAO-HNS CPT and RUC team members, Physician Payment Policy (3P) workgroup, and AAO-HNS EVP/CEO James C. Denneny III, MD, reviewed and provided feedback to RAND, on its draft survey.
- The Academy signed onto a Surgical Coalition letter expressing strong opposition to the draft survey and urging RAND to revise the survey to impose the least amount of burden possible on the physicians in the survey sample. To read the submitted sign-on letter, click here.