Suffice it to say that doctors are less than thrilled with a CMS physician fee schedule proposal that would require surgeons to report eight G codes starting Jan. 1 for services provided during 10- and 90-day global periods.
The plan, one of a trio of data collection efforts to help CMS more accurately value surgical procedures (
PBN 7/18/16), would cause all manner of administrative headaches, a series of physician representatives told CMS during an agency-sponsored meeting at CMS’s Baltimore offices Aug. 25.
Not only that, the unpaid G codes would probably cost practices money to report through their clearinghouses, the doctors said.
Reporting the codes would be “an interruption to work flow and burden upon patient care,” predicted Dr. David Glasser of the American Academy of Ophthalmology. As a result, “doctors will either skip [G code] reporting altogether or report just one code to save time,” and CMS’ data on global period services would be incomplete at best, he stated.
CMS would be better off doing the other two data collection efforts first, he suggested – including surveys of representative providers and site visits on a limited number of practices.
Specialty societies, which also are circulating a letter against the G codes among members of Congress, maintain that CMS overshot its statutory mandate – issued in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) – in even proposing the G-code program.
Definition of ‘representative sample’ up for debate
MACRA, which did away with the sustainable growth rate, also forbade CMS from phasing out the surgical global periods, which the agency proposed to do in the 2016 fee schedule. Instead, Section 523 of the law requires CMS to “implement a process to gather, from a representative sample of physicians, beginning not later than Jan. 1, 2017, information needed to value surgical services.”
A “representative sample” does not mean “all physicians,” pointed out Dr. Linda Barney of the American College of Surgeons.
Or perhaps it doesn’t mean all codes. Instead of requiring G-code reporting for follow-up care after all 110 10-day global period codes and the more than 4,000 90-day global period codes, CMS should focus on codes with the highest volume, recommended the AMA’s Dr. Allan Anderson.
That would cut the list down to a more manageable 235 codes primarily billed by 20 surgical specialties, he added.
“We also thought of that,” responded Dr. Ryan Howe, director of CMS’ practitioner services division. But “if you have concurrent surgeries, one on the high-volume list and one on the low-volume list, which do you report” the G codes for, he asked. And what about the burden on practices of having to consult different lists of high-volume and low-volume codes to know when to report the G-codes, he asked.
“It’s pretty intuitive which surgery is high volume or low volume,” Glasser snapped back.
Doctors prefer 99024
Instead of the eight G-codes, the doctors suggested that CMS require existing E/M 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).
That code is already integrated into Epic and numerous other EHR software systems, where the G codes would need to be input and might require a software update to be added, the doctors stated. In fact, a number of EHRs require the doctor to input code 99024 to “close out” or save documentation of a non-billable global period follow-up visit, Barney pointed out.
Still, even with code 99024, reporting global period services on claims would present a problem, she added. That’s because physicians typically wouldn’t have a billable reason to file a claim for global period follow-up care unless the patient has a complication that requires a return to the operating room.
“You submit the surgical claim as soon as the [surgical] service is completed” – not at the end of the global period, she explained. “In the end, you wouldn’t have a way to bill a claim with only non-billable codes on it. It makes no billing sense,” Barney told CMS officials.
CMS officials reminded doctors that their remarks during the town hall meeting were considered “unofficial comments” on the proposed fee schedule. File official comments at
www.regulations.gov by Sept. 6.