Global surgery data reporting requirements begin July 1

Starting July 1, select practitioners are required to report on post-operative visits finished during the global period for 293 specified procedures. Under the Medicare Access and CHIP Reauthorization Act of 2015, the Centers for Medicare & Medicaid Services (CMS) was required to implement data collection requirements for services furnished during the global period, including the definition of global periods, sampling approach, mechanisms for data collection, and definition of services furnished within the global period.

In 2016, CMS initially proposed all practitioners report on all 10- and 90-day global services with a series of G-codes starting January 1, 2017. However, through the regulatory advocacy work of the Academy and other medical specialty societies, CMS altered this proposal.

Practitioners in practices of 10 or more in Florida, Kentucky, Louisiana, Nevada, New Jersey, North Dakota, Ohio, Oregon, and Rhode Island will be required to report on claims data on post-operative visits furnished during the global period of a specified procedure using CPT code 99024 for procedures furnished on or after July 1, 2017. The specified procedures are those furnished by more than 100 practitioners and are either nationally furnished more than 10,000 times annually or have more than $10 million in annual allowed charges. A full list of the 293 specified procedures can be found at www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched/Downloads/Codes-for-Required-Global-Surgery-Reporting-CY-2017.zip.

In addition to collecting data from 99024, CMS conducted interviews of physicians and shadowed surgeries to further their understanding of post-operative visits during the global period. Academy members Douglas A. Girod, MD, and Steven M. Gold, MD, participated in interviews while representatives shadowed the practice of William R. Blythe, MD, for two days. CMS indicated the entirety of this data will be used to better inform future values for the global surgical package.

The Academy recently signed onto a  letter with many other medical specialties and organizations, advocating for CMS to postpone data collection until there is sufficient education for clinicians required to report 99024 and multiple implementation issues are clarified. While the Academy waits for RAND, the contractor working with  CMS on the data collection, to issue findings from the interviews and observation, we will continue to advocate for our members to ensure data collection processes do not impose an undue regulatory burden on practices.

The Academy will review and comment on all proposals in the upcoming proposed FY 2018 Medicare Physician Fee Schedule (MPFS) and will continue to meet with government officials and work with other medical specialty societies to minimize the burden on your practice as well as work to ensure the global surgical package is properly valued. You can find more information on CMS global surgical data collection at www.entnet.org/global.