Can Data Collection Put a Value on Surgical Services?
The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) requires the Centers for Medicare & Medicaid Services (CMS) to develop and implement a process to gather and analyze the necessary data on pre- and post-operative visits and other services furnished during global surgical periods other than the surgical procedure itself.
CMS proposes in the 2017 Medicare Physician Fee Schedule (MPFS) proposed rule to require reporting by any practitioner furnishing a service with a 10- or 90-day global period.
MACRA requires CMS to collect data to value surgical services starting Jan. 1, 2017, as part of its quality-based payment initiative. The data must include:
- The number and level of medical visits furnished during the global period, and
- Other items and services related to the surgery and furnished during the global period.
CMS intends to accomplish this using a three-pronged approach:
- Claims-based reporting on the number and level of pre-and post-operative visits;
- A survey of a representative sample of practitioners about the activities involved in and resources used in providing pre- and post-operative visits; and
- A more in-depth study including direct observation in a small number of sites, including accountable care organizations.
New G Codes
To allow claims-based reporting of post-op visits, the following set of no-pay codes were developed.
|Inpatient||GXXX1||Inpatient visit, typical, per 10 minutes|
|GXXX2||Inpatient visit, complex, per 10 minutes|
|GXXX3||Inpatient visit, critical illness, per 10 minutes|
|Office or Other Outpatient||GXXX4||Office or other outpatient visit, clinical staff, per 10 minutes|
|GXXX5||Office or other outpatient visit, typical, per 10 minutes|
|GXXX6||Office or other outpatient visit, complex, per 10 minutes|
|Via Phone or Internet||GXXX7||Patient interactions via electronic means by physician/NPP, per 10 minutes|
|GXXX8||Patient interactions via electronic means by clinical staff, per 10 minutes|
CMS is soliciting comments on how to use CPT® code 99024 Postoperative follow-up visit, normally included in the surgical package, to indicate that an evaluation and management service was performed during a postoperative period for a reason(s) related to the original procedure to capture the statutorily-required data on the number and level of visits.
The 2017 MPFS proposed rule describes features of the survey and approach that will be used, including the sample size of approximately 5,000 practitioners. Each of those responding practitioners will report on approximately 20 discrete visits during a fixed reporting period of approximately two weeks.
The third avenue for data collection outlined in the proposed rule is a set of direct observation activities, such as collecting information not amenable to survey-based reporting.
CMS admits it is unsure how the data will be used because there is no precedent. “What is clear,” CMS states in Section 523 of the 2017 MPFS proposed rule, “… we would know far more than we do now about how post-operative care is delivered and gain insight to support appropriate packaging and valuation.”
You can submit your comments to CMS through the normal notice and comment rule-making process, as described in the 2017 MPFS proposed rule.
Centers for Medicare & Medicaid Services; Data Collection on Resources Used in Furnishing Global Services Information Session; MLN Connects National Provider Call; Aug. 11, 2016