Drastic coding changes will put you on the auditor target list.
If you were hoping that the CMS proposal you read about in “Get the Scoop on Global Periods Coming Your Way in 2017” in the Practice Management Alert Vol. 14, No. 10, to do away with 10- and 90-day global surgical packages in the next few years was a hoax, we have bad news. CMS has confirmed in the 2015 Physician Fee Schedule Final rule that it will phase out global periods.
The good news is that we have the need-to-know info about how your practice can prepare, so you are ready when the implementation comes around.
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 will receive a lower surgical fee, and must 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:
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 mean more co-pays. Patients who are concerned about their out-of-pocket expenses may elect not to 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 urologist’s patterns of pre- and post-op visits associated with the most common surgical procedures performed in your practice. In that way, you will 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.
