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June 27, 2017



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Reminder: G-Code Reporting Starts July 1!

On Wednesday, November 2, 2016, the Centers for Medicare & Medicaid Services (CMS) issued a final rule that updates payment policies and payment rates for services furnished under the Medicare Physician Fee Schedule (PFS) on or after January 1, 2017. Originally, CMS proposed collection of post-operative data in three ways. The first prong would collect claims-based data on the number and level of visits in 10-minute increments from all physicians who perform Global Code (G-code) procedures. The second method would be a survey of physicians and the third would be data collection from the accountable care organizations (ACOs). The claims-based universal data gathering proposal was deemed extremely burdensome on our surgeons and not in line with the intent of the Medicare Access and CHIP Reauthorization Act (MACRA) statute. AAOS commented to CMS explaining these issues as well as joined other surgical specialties in legislative and regulatory advocacy efforts to urge CMS to reverse this proposal.

Subsequently, in the final rule with comments [Regulation No. CMS-1656-FC] (available online at:, CMS finalized three major flexibilities in reporting requirements as follows:

  1. CPT code 99024 can be used to collect data on the number of post-operative visits (as suggested by AAOS and others). Further, at this time, CMS will not require time units or modifiers to distinguish levels of visits to be reported.
  2. Instead of required reporting on all codes, CMS is just collecting data on the number of visits for codes that are reported annually by more than 100 practitioners and with high volume or high allowed charges (furnished more than 10,000 times or have allowed charges of more than $10 million annually as recommended by the RUC (AMA RVS Update Committee) and many other commenters including AAOS).
  3. Instead of collecting data from all physicians who perform global code procedures, CMS has finalized reporting requirements for a geographic sample of practitioners located only in the following states: Florida, Kentucky, Louisiana, Nevada, New Jersey, North Dakota, Ohio, Oregon and Rhode Island.

Moreover, the start date for implementation of such data collection was postponed from January 1, 2017 to July 1, 2017. At this time, CMS is not implementing the statutory provision that authorizes a 5 percent withhold of payment for the global services until claims are filed for the post-operative care, if required. The proposals regarding the physician survey and data collection in ACO has been finalized as proposed.

“CMS is hopeful that use of the existing CPT code for reporting these services will be significantly less burdensome than the proposal to require time-based reporting using the G-codes,” the agency wrote in a summary. “[W]hile practitioners are encouraged to begin reporting post-operative visits for procedures furnished on or after January 1, 2017, the requirement to report will be effective for services related to global procedures furnished on or after July 1, 2017. To the extent that these data result in proposals to revalue any global packages, that revaluation will be done through notice and comment rulemaking at a future time.”

AAOS is continuing to monitor this issue. For more information, read this recent AAOS Now article: