This week, ASCRS and the surgical community sent a letter to HHS Secretary Tom Price, MD, and CMS Administrator Seema Verma, expressing concerns with CMS’ global data surgery collection policy. The 2017 Medicare Physician Fee Schedule (MPFS) final rule requires data collection on post-surgical care from practitioners in practices of 10 or more practitioners furnishing specified ophthalmic 90-day global procedures in Florida, Kentucky, Louisiana, Nevada, New Jersey, North Dakota, Ohio, Oregon, and Rhode Island. The practitioners in the identified states are required to report all post-operative visits furnished during the global period of these procedures using CPT code 99024 beginning July 1, 2017. CMS plans to use the information collected to improve the accuracy of the valuation of surgical services; however, ASCRS and surgical community contend that there are still many outstanding questions that need clarification before this policy can move forward.
This final policy is the result of ASCRS and surgical community advocacy to prevent CMS finalizing its proposed policy, which was much more onerous and would have required all physicians furnishing global services to report on all post-operative care in 10-minute increments using G codes.
While CMS plans to hold an informational webinar on this policy next week (see separate story), our letter outlines aspects of the global data surgery collection that need further clarification, including the definition of what providers are considered “practitioners” and how is a group identified. Also, it is unclear if CMS has determined whether practitioners will be able to submit claims for 99024 for post-operative visits from any site of service or how surgeries billed with modifiers, such as for co-management, will be recorded. In addition, it is unclear if CMS has reached out to contractors to educate them on the required 99024 reporting, as some clearinghouses may reject them. Furthermore, it is unclear if a practitioner is required to submit two 99024 codes if he or she sees a patient more than once in a day. Clarification is also needed on how CMS will keep the appropriate 99024 attached to the index procedure in cases where more than one CPT code from the list of 293 codes are reported within the same global period. Finally, there are no instructions for how to code surgeries with modifiers, such as for co-management. CMS has yet to release a method for providers to confirm that the correct number of claims for 99024 have been captured.
We are working to delay the implementation of this data collection until CMS provides guidance. If CMS does not delay the implementation of the data collection, we strongly urge the agency to avoid using the data to revalue global services starting in 2019.