CMS global surgery data reporting

December 2017/January 2018 – Vol. 36, No. 11

The Centers for Medicare & Medicaid Services (CMS) is required to collect data on post-operative care following procedures with 10- and 90-day global periods. From the beginning of this effort, the AAO-HNS has been one of the specialties selected by the CMS contractor, RAND Corporation (RAND), for input. As a follow-up to the July 2017 article in the Bulletin, here is an update on AAO-HNS advocacy efforts on behalf of members.

October 2017:

The AAO-HNS CPT and RUC team members, Physician Payment Policy (3P) Workgroup, and AAO-HNS/F EVP/CEO James C. Denneny III, MD, reviewed and provided feedback to RAND on its draft development of a survey to collect information on the time, activities, and resources associated with post-operative visits. The primary concern AAO-HNS leadership expressed with the survey was that it only captured a “snapshot” in time, rather than the entire time the physician was caring for the patient. Also of concern were the number and level/intensity of post-op visits not being captured. These flaws are counter to the intent of the survey itself.

The AAO-HNS signed a Surgical Coalition letter expressing strong opposition to the use of the survey in its draft form, urging RAND to revise the survey to capture relevant information about post-operative visits using a format that is clear, straightforward, and logical. Further, the letter emphasized that the survey should impose the least amount of burden possible on the physicians in the survey sample.

The AAO-HNS awaits follow-up from RAND on the concerns about the survey and is hopeful the survey will be delayed until changes can be made. AAO-HNS also awaits further clarification from CMS regarding a detailed plan for data validation that provides assurance the data submitted will be accurately processed and connected to correct index codes. More information will be shared with members as soon as it is available. Visit to see CMS’ global surgical data collection.