If CMS has its way, the multi-day global surgical package — which “bundles” all related services provided within a specified time of major or minor medical procedures into a single payment — soon will be, no more. If adopted, the plan would change significantly how CMS values CPT codes and pays for post-procedure follow up, and likely would lead to increased demand for primary-care services.
The 2015 Physician Fee Schedule Proposed Rule, published in the July 11 Federal Register, includes a proposal (section II.B.4) to transition all CPT codes currently assigned a 10-day global period to a 0-day global period in 2017. Codes assigned a 90-day global period would transition to a 0-day global period the following year.
According to CMS, “The typical number and level of post-operative visits during global periods may vary greatly across Medicare practitioners and beneficiaries,” leading the agency to conclude “that continued valuation and payment of these face-to-face services as a multi-day package may skew relativity and create unwarranted payment disparities.” CMS cites additional reasons that bundling of services into the 10- and 90-day global periods may result in inaccurate (i.e., too high) payments, including:
• … payment rates for the global surgery packages are not updated regularly based on any reporting of the actual costs of patient care.
• … the relationship between the work RVUs for the 10- and 90-day global codes (which includes the work RVU associated with the procedure itself) and the number of included post-operative visits in the existing values is not always clear.
• … the 10- and 90-day global periods reflect a long-established but no longer exclusive model of post-operative care that assumes the same practitioner who furnishes the procedure typically furnishes the follow-up visits related to that procedure.
If CMS successfully eliminates 10- and 90-day global periods, all codes would be revalued to exclude services previously included within the global period. Only same-day, related services would be bundled into payment for any procedure, and any “medically reasonable and necessary visits … during the pre- and post-operative periods” would be separately billable.
As a further result, primary-care providers are likely to be called on more often to provide follow-up care (primarily, evaluation and management services) that surgeons and specialists have been required to provide due to the global surgery rules.
CMS is currently seeking comments on this proposed change, as well as others outlined in the 2015 PFS proposed rule. All comments must be received by 5 p.m. September 2, 2014. See the proposed rule for commenting instructions.