Medicare Compliance & Reimbursement

Hint: Be vigilant when reading the op notes.

Complex procedures sometimes require a second set of hands. When reporting co-surgery or assistant surgery for a service, you must read the notes carefully to avoid shorting your practice money — or collecting too much. Consider the following quick tips straight from Medicare’s regulations to ensure that you’re reporting these services properly.

What is co-surgery? “Co-surgery refers to a single surgical procedure which requires the skill of two surgeons, each in a different specialty, performing parts of the same procedure simultaneously,” CMS’s Transmittal 1781 says. “Co-surgery has been performed if the procedure(s) performed is part of and would be billed under a single surgical procedure code.

Co-surgery differs from surgical assists, because during an assist, one physician is the primary surgeon and the other doctor assists him. But if two surgeons “work together as primary surgeons performing distinct part(s) of a single reportable procedure, each surgeon shall report his/her distinct operative work by reporting the same surgical procedure code and the 62 modifier (Two surgeons),” CMS notes in the new transmittal 1781.

If your physician performs a surgical assist rather than a co-surgery, you’ll report modifier 80 (Assistant surgeon) instead of modifier 62 to the surgical procedure code.

Bottom line: Most carriers pay co-surgery claims by reimbursing the procedure code at 125 percent and splitting that between the two surgeons (thus, each surgeon gets 62.5 percent of the fee schedule amount). For surgical assists, Medicare reimburses assistant surgeons at 16 percent of the regular fee schedule amount, according to Section 20.4.3 of the Medicare Claims Processing Manual. This means that if you erroneously bill an assistant surgery instead of a co-surgery, you’re losing money.

The difference: Coders sometimes question whether an op note describes a co-surgery or a surgical assist. It can be hard to tell in some cases, but most doctors dictate on the op note to list them as “co-surgeons,” not as “surgeon” and “assistant surgeon,” and then they each dictate their own report.

Separate notes are key: When co-surgery is performed, each surgeon is required to dictate his or her own operative report, and they should put on the first page that it was a joint effort (“Co-surgeon Dr. B”) on it. “The report should also have numerous references about how Dr. A did this and then Dr. B did that and there should be lots of “we’s” throughout the report.

To read CMS’ Transmittal 1781,visit the CMS Web site at www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/downloads/R1781CP.pdf.