CMS Designates Global Surgery as “Potentially Misvalued Services”

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In the recently proposed 2015 Physician Fee Schedule, CMS devoted significant resources to discussing potentially misvalued services, which I believe is code for places where CMS would like to reduce reimbursement. One of the areas is global surgery fees.

CMS has concerns with the 10 and 90 day global surgery fees because these global packages were designed several decades ago when care was “more homogenous”, as described by CMS. CMS is now concerned that the resource utilization assumptions made for valuing these codes and establishing reimbursement rates are no longer valid, for such reasons as there are not as many follow-up visits, care is provided by different individuals in specialties which may or may not be included in the global surgery fee, and the span of time for the services has decreased.

CMS has stated the following expected benefits:

"We believe that transitioning all 10- and 90-day global codes to 0-day global codes would:

  • Increase the accuracy of PFS payment by setting payment rates for individual services based more closely upon the typical resources used in furnishing the procedures;
  • Avoid potentially duplicative or unwarranted payments when a beneficiary receives post-operative care from a different practitioner during the global period;
  • Eliminate disparities between the payment for E/M services in global periods and those furnished individually;
  • Maintain the same-day packaging of pre- and post-operative physicians’ services in the 0-day global; and
  • Facilitate availability of more accurate data for new payment models and quality research.

Therefore, CMS is proposing to eliminate the 10 and 90 day global surgery reimbursement models in 2017 and 2018 respectively, and simply pay separately for the surgical services and for follow-up visits and services that are provided by section of the global surgery payments will result in lower surgery payments, because CMS will now be assuming that other resources are going to be billed separately.

I have attached pages 40341 – 40348 of the Federal Register publication on July 11, 2014 regarding the 2015 proposed Medicare physician fee schedule for your review.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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