CMS Moves to Eliminate 10- and 90-Day Surgical Global Periods in Medicare

In the calendar year 2015 Medicare Physician Fee Schedule final rule, the Centers for Medicare and Medicaid Services (CMS) finalized its proposal to transition 10- and 90- day global surgical codes to 0-day globals.

Currently, Medicare provides a single, or bundled, reimbursement to physicians who submit claims with 10- or 90-day procedural global codes for all services related to the performed surgery for 10 or 90 days after including post-operative office visits. Approximately 4,200 of the over 9,900 Current Procedural Terminology (CPT) codes are 10- or 90-day global codes.

Under the new CMS policy, plastic surgeons would no longer submit a single claim for a surgery and its related post-operative office visits; instead, a claim would be submitted for the surgical procedure and a separate claim would be submitted for each medically necessary delivered post-operative office visit. Post-operative visits would be billed using the currently existing evaluation and management (E/M) codes.

However, CMS provided no information on the process it intends to pursue to disassemble the global codes and yet set an aggressive timeline for transitioning 10-day globals to 0-day globals by 2017 and 90-day globals by 2018.

In addition, patients currently make a single co-payment for their surgery and all related subsequent office visits.This new policy would require patients to make co-pays for, not only their surgery, but also for each subsequent post-operative office visit. This threatens to negatively affect patients financially and provides patients with a financial incentive to decline necessary post-operative care.

Given concerns about the impact on patients, the lack of methodology, and a failure to ensure that plastic surgeons will be adequately reimbursed for the surgeries they perform and the increased practice expenses incurred in post-operative office visits that are not included in typical E/M codes, ASPS has joined a broad coalition of physician organizations demanding more CMS transparency as well as a repeal of the policy given that CMS provided no details for physician and patient groups to review.

In addition to ASPS comments submitted to CMS as part of the Medicare Physician Fee Schedule rulemaking process, the coalition has sent a letter to members of Congress outlining the concerns with the policy and requesting legislative intervention. The coalition has also been conducting meetings with Congressional offices to discuss the issue and the need for legislative action.

These efforts have resulted in congressional champions including language in the draft 21st Century Cures bill released in January by the House Committee on Energy and Commerce. This language would prevent CMS implementation of the policy related to 10- and 90-day global codes. The coalition plans to continue its dialogue with congressional offices to ensure that CMS does not implement a policy that will undermine physician practices and directly and negatively impact patients.