EM Coding Alert

You may be paid individually for all the services performed in the global period.

CMS dropped big news in the Federal Register on July 11, 2014 with the announcement of a new proposed rule concerning potentially mis-valued services under the physician fee schedule. They propose eliminating 10-day and 90-day global periods and letting you bill services a la carte.

If the rule comes to fruition, this will impact any surgical procedures your physicians may perform, as well as what E/M service you can bill. Learn more about what CMS is saying about their proposal to be ready for changes to what needs to be coded separately.

Welcome Proposal Positives 

CMS wants to slowly transition the global periods for all codes to 0-day in an attempt to pay for what is truly being provided without duplication. Services that are medically necessary will be billed separately during pre- and post-operative periods. In CMS’s words, “We are proposing to transform all 10- and 90-day global codes to 0-day global codes beginning in CY 2017,” CMS stated in a fact sheet about the fee schedule proposal.

“The OIG has identified a number of surgical procedures that include more visits in the global period than are being furnished.” Because CMS seems to believe that Medicare is wasting cash by paying doctors for global periods that include visits the doctors don’t actually perform, CMS is proposing to include “all services provided on the day of surgery, and to pay separately for visits and services actually furnished after the day of the procedure …” says CMS in its fact sheet.

In the Federal Register, CMS explains that it believes by moving to only 0-day global codes, there will be positive outcomes, including:

• Increased accuracy of fee schedule payments by more accurately basing the rates on the resources used in the procedures
• Fewer duplicated payments when a patient receives post-op care from a different provider
• Elimination of payment discrepancies between E/M services provided in and outside of global periods 
• Retention of the pre- and post-operative services performed on the same day in the 0-day global
• More accurate data for new payment models and research.

You have a few years before the changes take effect, if the proposal goes through. The current 10-day global codes will transition to 0-day in 2017 and the 90-day in 2018. The actual dates will depend on when the analysis is completed for updating the global code values. This proposal isn’t final, but it may be in your best interest to familiarize yourself and your practice with the proposal that may benefit you in the future.

“I think that the majority of surgeons will be happy with this,” says Robin E. Richards, CPC, a senior coder in Pittsburgh, Pa. “When I worked as a surgery coder, there were physicians who looked closely at their charges every month and those surgeons will be very happy.”

“The surgeon will be able to bill for all visits she performs after surgeries such that the more difficult patients will be seen more and reimbursement will better reflect the care provided,” adds Suzan Berman (Hauptman), MPM, CPC, CEMC, CEDC, director of coding operations-HIM at Allegheny Health Network in Pittsburgh, Pa. “The less complicated patients who are not seen very often will certainly reflect differently on the bottom line. If your case load is fairly balanced, you shouldn’t notice a drastic change (depending on how much they decrease the RVUs of the surgical codes).”

Watch for Downsides, Too

A concern of CMS is that allowing separate payment of E/M visits during post-operative periods will promote unnecessary office visits during post-op periods. Because of this, they will monitor any changes in the use of E/M visits and welcome any payment policy suggestions that will mitigate that kind of change in behavior. 

Another less than optimal side effect may be the possible negative impact to patients. The more complex cases may have more post-op care visits that mean more co-pays.

“Those physicians who normally have more complicated patients with more post-op care could see a slight increase in the bottom line, but it might be at the expense of the patient having to pay more co-insurance,” suggests Hauptman. “The patients may be upset at having to pay co-pays for visits related to their recent surgery. If they do not have supplemental insurance this could be burdensome.”

Read more: To read the fact sheet, visit www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2014-Fact-sheets-items/2014-07-03-1.html. You can review the Federal Register article in its entirety at www.federalregister.gov/articles/2014/07/11/2014-15948/medicare-program-revisions-to-payment-policies-under-the-physician-fee-schedule-clinical-laboratory.