Advocacy News

July 19, 2016

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Change in Global Surgery Payment Policy

Bonefied News

CMS continues to allow a 90-day reporting period for Electronic Health Records (EHR) in 2016

Strengthening our Nation’s Trauma Care System

The Sports Medicine Licensure Clarity Act Passes Committee

Senate Finance Committee Holds MACRA Hearing

What We’re Reading

Representative Steny Hoyer’s Georgetown Law Lecture

Election 2016 Graphic of the Week

Stark Law Hearing

Pediatric Spinal Deformities

Expanding Uses of Medicare DATA by QE

The Orthopaedic PAC Capitol Club

AAOS Orthopaedic PAC Online Contribution Center

 
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Change in Global Surgery Payment Policy

On July 7, 2016, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that updates payment policies, payment rates, and quality provisions for services furnished under the Medicare Physician Fee Schedule (PFS) on or after January 1, 2017. The proposed rule addressed several aspects of physician payment policy, including a proposal regarding collecting data on services provided during the post-operative period.

Specifically, CMS is proposing to begin collecting data to determine post-operative office and facility visit patterns in 10- and 90- day global codes for procedures furnished on or after January 1, 2017.These codes would be included on claims filed through the usual process and will have to be reported in 10 minute increment of post-surgical care provided by physicians in the hospital, at the office or via email/telephone. It is to be noted that for FY 2017, CMS is not proposing any changes in values at this time, and will look to implement any changes indicated by the data collected in 2018 in future rules. 

While CMS is statutorily [per the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)] required to collect data on the number and level of visits to accurately value global services, AAOS believes that this rule has not correctly interpreted Congressional intent by requiring reporting in 10 minute increments and it will be extremely burdensome for our surgeons. Previously, CMS had attempted to alter the way surgical services billed with a 10 and 90 day global period, which bundled post-operative visits made by the physician for the patients undergoing the surgery by transforming all 10 and 90-day global codes to 0-day global codes, beginning in CY 2018. Under this policy, CMS would have valued the surgery or procedure to include all services furnished on the day of surgery and paid separately for visits and services furnished after the day of the procedure. AAOS strenuously worked to overturn this policy through legislative and regulatory initiatives. Subsequently, Congress enacted Section 523 of the MACRA prohibiting CMS from implementing this policy and requiring the agency to gather data on visits in the post-surgical period that could be used to accurately value these services.

Further, per this proposed rule, CMS asked RAND to collect and analyze data on (1) comprehensive claims-based reporting about the number and level of pre- and postoperative visits furnished for 10- and 90-day global services; (2) a survey of a representative sample of practitioners about the pre- and post-operative activities during a specified, recent period of time, such as two weeks; (3) a more in-depth study, including direct observation of the pre- and post-operative care delivered in a small number of sites, including some ACOs.

AAOS will provide extensive comments to CMS on this and other proposals under the Medicare Physician Fee Schedule proposed rule.  Comments on the proposed rule are due September 6, 2016.