Global Periods, Part 2:
To Bill or Not to Bill Post-Op Complications?
Published on Thu May 01, 2003
Although not uncommon, complications following surgery are an uncommonly troublesome coding challenge. Because the CPT and CMS definitions of "typical postoperative care" differ significantly, whether to report post-op complications depends on the payer as well as the service(s) or procedure(s) provided. What's Typical? It Depends Whom You Ask Under the concept of a global surgical package, carriers bundle or include payment for services integral to a surgical procedure as a part of the procedure and not independently reportable for separate reimbursement, says Barbara J. Cobuzzi, MBA, CPC, CPC-H, CHBME, president of Cash Flow Solutions Inc., a physician reimbursement consulting firm in Lakewood, N.J., and vice president of the Coding and Reimbursement Network. For example, compensation for writing orders and conducting hospital rounds during the postoperative period is included in the payment for the surgical procedure, as are other aspects of "typical postoperative follow-up care." But CPT and Medicare differ in their definitions of "typical" postoperative care. What Medicare recognizes as a part of the global surgical package CPT might define as a separately reportable complication. CPT specifies that follow-up for therapeutic surgical procedures "includes only that care which is usually a part of the surgical service. Complications, exacerbations, recurrence or the presence of other diseases or injuries requiring additional services should be separately reported." Similarly, follow-up for diagnostic surgical procedures "includes only that care related to recovery from the diagnostic procedure itself. Care of the condition for which the diagnostic procedure was performed or of other concomitant conditions is not included and may be listed separately."
CMS is much more inclusive and bundles into the global package all additional medical or surgical services required of the surgeon during the postoperative period of the surgery because of complications. The only exceptions occur when the complications are unrelated to the surgery or require a return to the operating room (OR). Finally, treatment for the underlying condition or for an added course of treatment that is not part of the normal recovery from surgery (see list, below), as well as all follow-up visits within the postoperative period of the surgery that are related to recovery from the surgery, is separately reportable. Medicare also specifically includes the following as part of the global package:
dressing changes
local incisional care
removal of operative pack
removal of cutaneous sutures and staples, lines, wires, tubes, drains, casts and splints
insertion, irrigation and removal of urinary catheters, routine peripheral intravenous lines, nasogastric and rectal tubes
changes and removal of tracheostomy tubes. CMS guidelines further note, "The services included in the global surgical package may be furnished in any setting, e.g., in hospitals, ASCs, physicians'offices. Visits to a patient in an intensive care [...]
