CMS released its 2015 Proposed Physician Fee Schedule Rule at 5 pm July 3, 2014. Right before a three day weekend. But, since I’m giving a webinar on the rule July 10, I read away, in between soccer and fireworks. Over the next few weeks, I’ll post summaries of some of the proposals in the rule. On Halloween (CMS loves holidays), when the 2015 Final Rule is released, I’ll add additional posts.
CMS is proposing changes to the definition of the global period, effective in 2017 and 2018. Now, these are proposals and CMS is requesting comments from stakeholders. Nothing in the Proposed Rule is decided on! CMS notes that the payment for 3000 surgical CPT codes includes pre-operative services, intraoperative services and post-operative care. The Office of Inspector General did two reviews, one of Ophthalmology surgical care and one of Orthopedic care. They reviewed the medical records and determined how much post-op care was provided for a sample of these codes. They found that the “value” of the post-op care was less than the value assumed in the surgical care code. Sometimes, the patient receives follow up care elsewhere, and in that case, that physician reports an E/M code. Sometimes, the patient elects not to follow up. The value of the surgical code is built assuming a certain number of follow up visits, and these are not always needed or performed. The value of the codes is assumed to be provided in the office, in a non-facility status. But, some of the services are provided in provider based clinics which have facility status and have lower value. All in all, CMS believes that these global surgical codes may be mis-valued. They are soliciting comments on their proposal to remove post-op care from surgical codes with 10 global days in 2017 and for surgical codes with 90 global days in 2018. It is a proposal and they are asking for our thoughts, opinions and reactions.
It might not be a bad idea. The complaint I hear from most surgeons is about the outliers in the other direction. The post-op patient with multiple co-morbidities who has a non-healing wound and needs more frequent and intense follow up. If there is a mechanism for being paid for those cases, it would be a relief to many surgeons.