Otolaryngology Coding Alert

Plus: If CMS prevails, you may get paid less for surgical procedures.

Global periods affect every provider’s coding, billing, and reimbursement, whatever the specialty and place of service might be. Figuring out when you can and can’t bill office visits for patients who have recently had a procedure performed may get easier, thanks to a proposed rule from CMS for the Medicare Physician Fee Schedule (PFS).

Read on for the scoop about CMS’s plan to eliminate global periods for surgical procedures and how the changes could affect your practice’s bottom line. 

Say Good-bye to 10- and 90-Day Global Periods – Maybe 

You might be surprised to learn what CMS is suggesting. “We are proposing to transform all 10- and 90-day global codes to 0-day global codes beginning in CY 2017,” CMS says in a fact sheet about the fee schedule proposal.

Here’s why: According to CMS, “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 …” CMS states in its fact sheet.

Impact: This would mean you could bill any postoperative services on an a la carte basis instead of bundling all related post-operative care into the surgical charge. 

“Surgeons may welcome this change, but whether it bodes well or ill for practices really depends on how CMS decides to value the surgical codes once the agency removes the global periods from the value units,” says Marcella Bucknam, CPC, CPC-I, CCS-P, CPC-H, CCS, CPC-P, COBGC, CCC, internal audit manager with PeaceHealth in Vancouver, Wash.

Possible perspective: Every procedure has a percentage of its fee allocated for pre-op, intraoperative, and post-op work. “If CMS felt that those were fairly assigned now, I would think they would take away the post-op percentage of the fee,” says Barbara J. Cobuzzi, MBA, CENTC, CPC-H, CPC-P, CPC-I, CHCC, president of CRN Healthcare Solutions, a consulting firm in Tinton Falls, N.J. “For example, the post-op percentage for a septoplasty is 14 percent. So bringing that code (30520) to a zero global day would reduce the Medicare fee by 14 percent. But, keep in mind that this is possibly taking effect in 2017, and we aren’t sure if CMS will use this methodology.” 

Caution: If CMS goes through with this proposal, the agency will be watching patterns of billing post-op E/M services. “We [want to] ensure that allowing separate payment of E/M visits during post-operative periods does not incentivize otherwise unnecessary office visits during post-operative periods. If we adopt this proposal, we intend to monitor any changes in the utilization of E/M visits following its implementation.”

Remember: During 0-, 10-, and 90-day global periods, you shouldn’t separately bill E/M services that are part of the normal pre-op, surgical, or post-op care. That includes any E/M procedure provided during the post-operative period that is related to the recovery from the surgery, including pain management. The proposal to eliminate global periods could change all that. Stay tuned to Otolaryngology Coding Alert for updates as they become available. 

Learn more: You can read the CMS proposal and find out how to comment at www.federalregister.gov/articles/2014/07/11/2014-15948/medicare-program-revisions-to-payment-policies-under-the-physician-fee-schedule-clinical-laboratory.