CMS Proposes Eliminating Global Surgical Packages
Medicare’s 2015 Physician Fee Schedule Proposed Rule includes a plan to eliminate 10- and 90-day global periods for all CPT® procedure codes, beginning in 2017. If adopted, the plan would radically change how the Centers for Medicare & Medicaid Services (CMS) values procedures, as well as how it pays for post-procedure follow up.
Section II.B.4 of the proposed rule—properly titled “Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule, Clinical Laboratory Fee Schedule, Access to Identifiable Data for the Center for Medicare and Medicaid Innovation Models & Other Revisions to Part B for CY 2015” and published in the Federal Register July 11—argues that the bundling of related services during 10- and 90-day global periods often result in inaccurate payments for several reasons, including:
- … the payment rates for the global surgery packages are not updated regularly based on any reporting of the actual costs of patient care.
- … payment for the PFS [physician fee schedule] global packages relies on valuing the combined services together. This means that there are no separate PFS values established for the procedures or the follow-up care, making it difficult to estimate the costs of the individual global code component services.
- … the relationship between the work RVUs [relative value units] 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. In many cases, we believe that models of post-operative care are increasingly heterogeneous, particularly given the overall shift of patient care to larger practices or team-based environments.
The proposed rule goes on to lament “the fundamental difficulties in establishing appropriate relative values for these [global] packages, the potential inaccuracies in the current information used to price these services, the limitations on appropriate pricing in the future, the potential for these packages to create unwarranted payment differentials among specialties, the possibility that the current codes are incompatible with current medical practice, and the potential for these codes to present obstacles to the adoption of new payment models.”
The proposed rule further cites a 2012 Office of Inspector General (OIG) report that concluded the RVUs assigned to selected global surgical packages “are too high because they include a higher number of E/M services than typically are furnished within the global period for the reviewed procedures.”
Considering the above evidence, CMS does “not believe that maintaining the post-operative 10-and 90- day global periods is compatible with our continued interest in using more objective data in the valuation of PFS services and accurately valuing services relative to each other.” As a solution, the agency proposes transitioning all 10- and 90-day global codes to 0-day global codes.
Procedures with 10-day global periods would transition to 0-day global periods in 2017, while procedures with 90-day global periods would transition to 0-day global periods in 2018.
As such, all codes would be revalued to exclude services previously included within the global period. In other words: The current valuation for procedures with 10- or 90-day global periods would be adjusted downward, but providers would be allowed to report “medically reasonable and necessary visits … separately during the pre- and post-operative periods outside of the day of the surgical procedure.” In sum, CMS implicates that this would lower total overall payments.
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.