Don’t Ignore 99024; Reporting Is Now a Requirement

Don’t Ignore 99024; Reporting Is Now a Requirement

Although you may not think you get paid for it, it’s included in the payment for surgery.

In July 2017, the Centers for Medicare & Medicaid Services (CMS) began requiring medical offices with 10 or more practitioners in nine states (Florida, Kentucky, Louisiana, New Jersey, Nevada, North Dakota, Ohio, Oregon, and Rhode Island) to report claims data on post-operative visits furnished during the global period of specified procedures (see Chart A) using CPT® 99024 Postoperative follow-up visit. Code 99024 captures services normally included in the surgical package, indicating an evaluation and management (E/M) service was performed during a postoperative (post-op) period for a reason(s) related to the original procedure.

Note: Codes that are striked through were deleted for 2018 and no longer apply.

Chart A: CMS-designated CPT® Procedures for Reporting Post-op Visits (99024)

10040 11442 12034 15120 17282 23120 27134 28308 33207 36589 44143 49650 63047 65855 67840

10060 11443 12041 15240 17283 23412 27235 28470 33208 36590 44145 50360 63056 66170 67900

10061 11601 12042 15260 19120 23430 27236 28510 33228 36819 44160 50590 63081 66179 67904

10120 11602 12051 15732 19125 23472 27244 28810 33249 36821 44204 52601 63650 66180 67917

10140 11603 12052 15734 19301 23500 27245 28820 33263 36830 44205 52648 63685 66711 67924

10160 11604 13101 15823 19303 23600 27446 28825 33264 36832 44207 53850 64555 66761 68760

10180 11606 13121 17000 19307 23615 27447 29822 33282 37607 44970 54161 64561 66821 68761

11200 11621 13131 17004 19357 23650 27486 29823 33405 37609 46221 55866 64581 66982 68801

11400 11622 13132 17110 20670 25447 27487 29824 33426 37765 46500 57240 64590 66984 68810

11401 11623 13151 17111 20680 25600 27506 29827 33430 37766 46930 57288 64612 67036 68840

11402 11640 13152 17260 20926 25605 27590 29828 33533 38500 47562 58571 64615 67040 69420

11403 11641 13160 17261 22513 25607 27786 29848 33860 38525 47563 58661 64616 67041 69433

11404 11642 14020 17262 22514 25609 27814 29876 34802 38571 47600 60240 64617 67042 69436

11406 11643 14021 17263 22551 26055 27880 29879 34825 38724 49422 60500 64632 67108

11420 11644 14040 17270 22558 26160 28122 29880 35301 40808 49440 61312 64633 67113

11421 11646 14041 17271 22600 26600 28124 29881 36470 43281 49505 61510 64635 67145

11422 11750 14060 17272 22612 26720 28232 30140 36471 43644 49507 62264 64640 67210

11423 11765 14061 17273 22630 27125 28270 30520 36558 44005 49560 63030 64718 67228

11440 12031 14301 17280 22633 27130 28285 32480 36561 44120 49561 63042 64721 67255

11441 12032 15100 17281 22830 27132 28296 32663 36581 44140 49585 63045 65756 67800

Source:
CMS MLN Connects® National Provider Call, Global Surgery: Required Data Reporting for
Post-operative Care Call. April 25, 2017

Understand the Purpose of 99024

CPT® 99024 is a Medicare bundled code with zero relative value units (RVUs) and no fee on the Medicare Physician Fee Schedule (MPFS), so you may wonder why CMS is interested in collecting this data. In fact, a Medicare bundled code is reimbursed by Medicare, but not at the time the service is performed. According to the MPFS, “… payment for them is subsumed by the payment for the services to which they are incident.” In other words, payment for post-op care “tomorrow” is included in payment for the surgery “today.”

Because Medicare pays for the service “in advance,” it is appropriately interested in whether those services are performed. Thorough post-op care reduces the risk of complications of surgery (including pain), helps to manage side effects of treatment, and supports recovery.

Post-op Care Documentation Responsibilities

The responsibility for post-op care falls primarily to the person who is reimbursed for the surgery, usually the surgeon. In hospitals, anesthesiologists sometimes may assume these duties when post-op specialty care is required or preferred for best outcomes. In the outpatient setting, sometimes post-op care is performed by physician assistants incident-to the physician service (although, the American College of Surgeons seems to discourage this practice).

According to the American College of Surgeons’ Documentation of Services Provided in the Post-operative Global Period, these visits do not need to be documented the same way other E/M visits are documented, but should describe the medical necessity for the visit; the status of the patient’s recovery from the procedure; post-op counseling provided; diagnostic tests ordered; referrals or consultations recommended; the nature of the patient’s original and underlying problems; and the severity of the original symptoms.

CMS Tracks Post-op E/M Services for OIG

The global surgical package has been developed to include a typical number of pre- and post-op services. For example, payment for CPT® 22612 Arthrodesis, posterior or posterolateral technique, single level, lumbar includes payment for seven E/M services. More or fewer services may be provided according to the surgeon’s judgment.

In 2012, the Office of Inspector General (OIG) published Musculoskeletal Global Surgery Fees Often Did Not Reflect the Number of Evaluation and Management Services Provided. According to the study, Medicare paid a net $49 million for E/M services that were included in the musculoskeletal fees, but were not provided during the global surgery periods in 2007. As a result of this study, the OIG recommended CMS adjust the estimated number of E/M services within musculoskeletal global surgery fees to reflect the actual number of E/M services provided to patients, and to use the results of this audit during the annual update of the MPFS. In effect, this would reduce the payment for surgeries.

CMS agreed with the OIG’s recommendation, but appropriately decided to gather more data first. One reason for their decision to gather more data was that CMS realized not all surgeons who perform post-op visits report 99024. If CMS is to use reported data to determine the fee schedule, then accurate data is essential: Surgeons must report all post-op care they provide using 99024.

CMS also noted that, although they would consider reducing the global payments if the data indicated that the typical post-op work for surgeries had changed, any “changes to the values of services under the PFS must be done in a budget neutral manner as required by the Medicare statue” (Musculoskeletal Global Surgery Fees Often did not Reflect the Number of Evaluation and Management Services Provided, OIG). In other words, if surgeons in the nine targeted states don’t thoroughly report all of their post-op visits using 99024, surgeons in all states may lose money to other medical specialties.

It’s About Capturing Physician Work in Patient Care

Reporting 99024 for post-op care will not only help to ensure surgeons are reimbursed adequately for all the work they perform, but also serve as a reminder of the value and importance of post-op physician visits in achieving better health outcomes for patients.


Resources

CMS MLN Connects® National Provider Call, Global Surgery: Required Data Reporting for Post-operative Care Call. April 25, 2017: www.cms.gov/Outreach-and-Education/Outreach/NPC/Downloads/2017-04-25-Global-Surgery-Presentation.pdf

Documentation of Services Provided in the Post-operative Global Period, Bulletin of the American College of Surgeons, May 1, 2013: http://bulletin.facs.org/2013/05/documentation-of-services/#.WhM2_1WnGM8

Musculoskeletal Global Surgery Fees Often did not Reflect the Number of Evaluation and Management Services Provided, OIG, May 2012, Appendix D: CMS Comments, page 2: https://oig.hhs.gov/oas/reports/region5/50900053.pdf


Brian Meredith, CPC, is president and founder of Healthforce, Inc., a healthcare administrative consulting firm focusing on revenue integrity through compliance, coding and billing guidance. He has over 20 years’ experience in the healthcare industry, including former director of billing compliance at Boston Children’s Hospital;, compliance and coding consultant with Public Consulting Group in Boston; and compliance specialist with UMass Memorial Medical Group. Meredith is a member of the Holyoke, Mass., local chapter.

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