General Surgery Coding Alert

Don’t increase your follow-up care.

You’ve seen CMS’s proposal to eliminate 10- and 90-day surgical packages, but have you thought through what it could mean for your bottom line?

True, the global surgical package re-vamp that you read about in General Surgery Coding Alert Vol. 16, No. 9 is still a proposal with a distant implementation date. But you should study your current practice standards now, because Medicare will be watching for a change in your behavior if and when all surgeries convert to 0-day.

Look for Re-Valuation

The proposal to make all surgeries 0-day affairs means that CMS would not continue to pay for the affected codes at the same rate. 

“Under the mis-valued code initiative, the surgical code would be re-valued to include only those services provided on the day of surgery, and to pay separately for visits or services actually furnished after the day of the procedure,” explains Joann Baker, CCS, CPC, CPC-H, owner of Precision Coding and Compliance, LLC in Hackettstown, N.J. 

That could mean you’ll get a lower surgical fee, but have to file additional claims for pre-op or follow-up E/M services.

“Since the base procedure valuation may change, preparing for the adjustment in revenue and an increase in claim reporting volume may need to be assessed while all visits and services to the patient are completed and billed,” Baker says. 

Timeline: Under the proposal, the current 10-day global codes will transition to 0-day in 2017, and the 90-day will change to 0-day in 2018. The actual dates will depend on when CMS completes the analysis for updating the global code values.

Understand Pros and Cons

CMS identified global surgical packages as a problem to be fixed based on OIG reports. “The OIG has identified a number of surgical procedures that include more visits in the global period than are being furnished,” CMS states in the proposal. 

Solution: 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.

Upside: “I do think surgeons will welcome this change because it simplifies office billing procedures,” says Freda Brinson, CPC, CPC-H, CEMC, compliance auditor at St. Joseph’s/Candler Health System in Savannah, Ga. “No longer will surgical dates have to be remembered, counted, and calculated as to when a visit can be billed; no longer will there be the need to stress out over ‘is this really related’ to the procedure.”

Downside: One concern about the change to 0-day is a possible negative impact on patient care. More complex surgical cases may entail more post-op care visits, which means more co-pays. Patients who are concerned about their out-of-pocket expenses may elect to not go for the appropriate follow-up care.

Don’t Change Your Follow-Up Patterns

Another concern expressed by CMS is that allowing separate payment for E/M visits during post-operative periods will promote unnecessary office visits, and an increase in E/M services overall. Because of this, concern CMS has stated its intention to monitor any changes in the use of E/M visits associated with surgical procedures. 

Do this: Perform an internal audit now to elucidate and document your surgeons’ patterns of pre- and post-op visits associated with the most common surgical procedures you perform in your practice. That way, you’ll have a baseline to monitor your billing practices after the global-package change goes into effect — and documentation to lean on if a CMS auditor comes calling. 

Resource: You can review the relevant Federal Register notice 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.