Medicare Compliance & Reimbursement

Hint: Not all services are bundled into a global surgical period.

In most cases, you can report these services separately and collect for them.

A gray area exists for coders when it pertains to global packages. That’s because when you’re dealing with global surgical periods, it can be easy to assume that all of the services you perform during the global period are bundled into your surgical reimbursement. However in most cases, you can report these services separately and collect for them.

According to the Medicare Learning Network’s “Global Surgery Fact Sheet,” you can bill separately for the following services if you perform them during the global surgical period of a procedure:

1. The visit that determines the need for surgical intervention. This is the decision for surgery, and if the visit occurs on the day before or day of surgery, append modifier 57 (Decision for surgery) to the E/M code to when the procedure is considered a major surgical procedure, the fact sheet says.

However, the fact sheet notes, “the initial evaluation for minor surgical procedures and endoscopies is always included in the global surgery package,” so you can only use modifier 25 (Significant, separately identifiable evaluation and management service by the same physician or other qualified healthcare professional on the same day of the procedure or other service) with the E/M performed on the day of or the day before a minor procedure if the documentation demonstrates a significant, separately identifiable E/M service.

2. Services of other physicians related to the surgical procedure. Unless the two physicians agree to a transfer of care, the second doctor’s services are not subject to the first doctor’s global period.

3. Visits unrelated to the diagnosis that led to the surgery. Unless the doctor is treating an unrelated diagnosis that only exists due to surgical complications from the surgery that prompted the global period, you can separately report the E/M service. You’ll typically need to append modifier 24 (Unrelated evaluation and management service by the same physician or other qualified healthcare professional during a postoperative period) to the E/M code.

4. Treating the underlying condition that isn’t related to normal surgical recovery. This also relates to adding a course of treatment that isn’t part of normal recovery. In most cases, you’ll have to append modifier 79 (Unrelated procedure or service by the same physician or other qualified healthcare professional during the postoperative period) to the procedure code.

5. Diagnostic tests and procedures, including radiological procedures performed for diagnostic purposes.

6. Additional surgeries that aren’t related to the surgery that prompted the global period. If the new surgery has nothing to do with the original surgery and is also not related to treating complications, you can separately report that. You’ll typically append modifier 79 (Unrelated procedure or service by the same physician or other qualified healthcare professional during the postoperative period).

7. Treating postoperative complications, as long as the patient has to go back to the operating room. In most instances, you’ll have to append modifier 78 (Unplanned return to the operating/procedure room by the same physician or other qualified healthcare professional following initial procedure for a related procedure during the postoperative period) to the new surgical code after taking the patient back to the OR.

8. A more extensive procedure, if required because the initial, less extensive procedure fails. You’ll typically append modifier 58 (Staged or related procedure or service by the same physician or other qualified healthcare professional during the postoperative period) to these services, because the descriptor refers to a “related” procedure.

9. Immunosuppressive therapy for organ transplants. Immunosuppressive therapy may be used in corneal transplants, but isn’t always utilized, so check the documentation before you report it in these cases.

10. Critical care services unrelated to the surgery when the patient needs constant physician attendance. You’ll report these with codes 99291-99292 (Critical care, evaluation and management of the critically ill or critically injured patient…). Your payer should not require a modifier for these codes, but if it does, you’ll append modifier 24 (Unrelated evaluation and management service by the same physician or other qualified healthcare professional during a postoperative period).

Resource: To read Medicare’s Global Surgery Fact Sheet, visit https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/downloads/GloballSurgery-ICN907166.pdf.