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Global Surgery Data Collection

Practitioners in Florida, Kentucky, Louisiana, Nevada, New Jersey, North Dakota, Ohio, Oregon, and Rhode Island are required to report on claims data on post-operative visits furnished during the global period of specified procedures using CPT code 99024, beginning July 1, 2017. The specified procedures are those that are furnished by more than 100 practitioners and either are nationally furnished more than 10,000 times annually or have more than $10 million in annual allowed charges. Practitioners who only practice in practices with fewer than 10 practitioners are exempted from required reporting, but are encouraged to report if feasible. Although reporting is required for global procedures furnished on or after July 1, 2017, we encourage all practitioners to begin reporting as soon as possible. 

CMS is required to collect data to use in valuing global surgical services by Section 1848(c)(8)(B) of the Social Security Act. For more information on the data collection effort, we refer readers to pages 80209 - 80225 of the CY 2017 PFS final (CMS-1654-F).   

In addition to this claims-based data collection, CMS has contracted with RAND to conduct a survey to collect additional data on pre- and post-operative services. For more information on the survey, we refer readers to pages 80222 - 80224 of the CY 2017 PFS final rule (CMS-1654-F).

Codes for Which Reporting on Post-Operative Visits is Required

The 2017 Physician Fee Schedule Final Rule requires some practitioners to report on post-operative visits furnished during global periods using CPT code 99024. The Final Rule specifies that reporting will be required only for post-operative visits related to procedure codes reported annually by more than 100 practitioners and that are either reported more than 10,000 times or have allowed charges in excess of $10 million annually. The Final Rule further specifies that CMS will use CY 2014 claims data to determine the specific codes for which reporting is required.  The list of codes for which such reporting is required beginning July 1, 2017 can be downloaded below. (For more details on the reporting requirements, see 81 FR 80209.)

To determine this list, we began with CY 2014 HCPCS codes with 10-or 90-day global periods (determined using Addendum B from the 2014 Physician Fee Schedules). In aggregating Medicare CY 2014 claims data, CMS used the same process used for setting PFS payment rates. Several adjustments were made to the resulting raw data before volume and allowed charges were aggregated. Bill lines with modifiers 55 (Postoperative Management Only), 56 (Preoperative Management Only), 80 (Assistant Surgeon), 81 (Minimum Assistant Surgeon), or 82 (Assistant Surgeon When Qualified Resident Surgeon Not Available) did not contribute to the HCPCS-level total volume to avoid double counting. Bill lines with modifier 62 (Two Surgeons) and 66 (Surgical Team) contributed only a half and one-third of the reported volume to the HCPCS-level total volume, respectively, to avoid double counting. Bill lines with modifier 50 (Bilateral Procedure) contributed twice the reported volume to the HCPCS-level total volume to reflect that the procedure was being done twice even though only one unit was billed. After these adjustments, allowed charges and units were aggregated by HCPCS and codes above either the allowed charge or volume threshold were selected for inclusion on the list.

As a final step, the 2014 HCPCS codes were translated, where necessary, to CY 2017 codes using the utilization crosswalks posted with the 2015, 2016, and 2017 Physician Fee Schedule Final Rules. As a result of this, the following changes occurred. 

2014 HCPCS Code

2017 Reporting List Action

21800

Deleted Code; Removed

36870

Deleted Code; Removed

22523

Deleted Code; Replaced with 22513

22524

Deleted Code; Replaced with 22514

27193

Deleted Code; Removed

65778

0-day global in CY 2017; Removed

66180

66179 New 2015; Added as Partial Substitute for 66180

In a separate analysis, claims data from CMS’s Integrated Data Repository were used to calculate the number of unique practitioners furnishing each of the procedure codes identified through the prior steps. All of the procedure codes on the list were furnished by more than 100 unique practitioners defined by National Provider Identifier (NPI).

G-codes

In the CY 2017 proposed rule, CMS proposed to use a set of no-pay G-codes to capture post-operative care on claims.  For more on this proposal see pages 46191 - 46200 of the CY 2017 proposed rule (CMS-1654-P).  In making our proposal, we relied heavily upon codes developed for reporting post-operative care by RAND under a contract with CMS. The RAND report is available in the download section below. Also, as part of this contract RAND was required to test the G-codes that CMS proposed to assess whether practitioners understood the codes and could accurately apply them. A RAND report detailing the results of this testing is available in the download section. 

Note: After consideration of the comments received on the proposed rule, CMS chose to use an existing CPT code for reporting post-operative care in the global surgery period.  As a result, the codes discussed in these reports do not exist.  

For Further Information

Contact MACRA_Global_Surgery@cms.hhs.gov