strongly urges all surgeons who
are required to report to comply
with this policy. Inaccurate
and incomplete data collection
may have a negative effect on
10- and 90-day global services.
How should practitioners
report postoperative visits?
Postoperative visits should be
reported through the usual
process for filing claims.
Practitioner, beneficiary, and date-of-service information should be
submitted. The postoperative
visit (the 99024 code) need not
be linked to the related 10- or
90-day global code, and it is not
necessary to add any modifiers.
Practitioners should follow usual
Medicare billing requirements
to demonstrate that visits were
provided and a code was correctly
used (such as a chart note).
How does CMS define a
“group” and how should
whether they are in a group
of 10 or more practitioners?
Both physicians and
nonphysicians count for the
purposes of determining whether
a group comprises 10 or more
health care practitioners. Unlike
other Medicare programs, CMS
does not define a group based
on a shared tax identification
number (TIN); rather, for these
purposes, practices are defined
as a group if their business or
financial operations, clinical
facilities, records, or personnel
are shared by two or more
practitioners (not necessarily
at the same physical address).
Practitioner count should
include all billing physicians
and nonphysician practitioners
regardless of whether they
are furnishing services under
an employment, partnership,
or independent contractor
model. For the purposes of
this policy, CMS will look at
whether practitioners share a
facility or other resources.
What if a practitioner
provides services in two
practices, but only one
meets the size threshold?
These practitioners are
required to report under
this policy. Practitioners are
required to report if they have
relationships with at least one
group of 10 or more health care
practitioners. Practitioners in
this situation must report all
eligible postoperative visits,
JUL 2017 BULLETIN American College of Surgeons
WHAT SURGEONS SHOULD KNOW ABOUT...
This mandatory policy is designed so that CMS can gather
enough data on postoperative visits to improve the accuracy
of global code values starting in 2019. If practitioners do
not report, CMS will be unable to collect accurate and
complete data, and reimbursements for 10- and 90-day global
services could be negatively affected in the future.
Starting July 1, CMS now
requires both physician and
nonphysician health care
practitioners in nine states to
report data on the number of
postoperative visits that they
provide for select 10- and
90-day global surgical codes.