Accurate coding and documentation are crucial in healthcare, especially for complex procedures like craniotomies. Ensuring appropriate reimbursement for global surgical packages, which include both the procedure and post-operative care, is vital for healthcare providers. This article delves into the strategies for improving payment accuracy, particularly concerning the post-operative care coding for craniotomy and similar neurosurgical interventions.
Medicare’s Physician Fee Schedule (PFS) incorporates a global surgical package, wherein a single payment covers the surgical procedure itself and all routine post-operative care within a designated period (0-10 or 90 days). Recognizing the need for data-driven valuation of these packages, the Centers for Medicare & Medicaid Services (CMS) has undertaken initiatives to collect data on post-operative services.
The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) mandated CMS to gather data on the frequency and intensity of post-operative visits. This data collection aims to refine the valuation of global surgical packages, ensuring that payments accurately reflect the resources utilized in providing comprehensive surgical care, including procedures like craniotomies that necessitate meticulous post-operative management.
For specific high-volume or high-cost procedures, including cataract surgery, hip arthroplasty, and complex wound repair, Medicare initiated a reporting requirement for select practitioners across nine states, starting July 1, 2017. These practitioners were required to report post-operative visits using CPT code 99024. The baseline for expected post-operative visits was established using the “time file,” which historically captured the number of visits factored into the initial valuation of these procedures.
CMS has compiled comprehensive lists of codes with global periods of 010 or 090 days, for which post-operative visit reporting has been mandated from 2017 through 2024. These lists, updated regularly and available for download, provide essential resources for healthcare providers to understand the reporting requirements and ensure accurate coding practices. These resources can be accessed in the following ZIP files:
PFS_Global_010_090_Reporting_PostOp_Visit_2024-2017_List_v01-25-2024.zip (ZIP)
PFS_Global_010_090_Reporting_PostOp_Visit_2024_List_v01-25-2024.xlsx (ZIP)
PFS_Global_010_090_Reporting_PostOp_Visit_2024_List_508_v01-25-2024.txt (ZIP)
Furthermore, RAND Corporation reports have explored the potential impact of re-evaluating procedures with 010- and 090-day global periods based on this newly collected post-operative visit data. The “reverse building block approach” analyzed in these reports suggests that incorporating actual post-operative visit data could lead to significant adjustments in the Relative Value Units (RVUs) assigned to surgical procedures under the Physician Fee Schedule. Understanding these potential revaluations is crucial for financial planning and accurate revenue cycle management within surgical practices.
In CY 2017, CMS considered utilizing a set of non-payment G-codes to specifically capture post-operative care on claims. This proposal, detailed in the CY 2017 proposed rule (CMS-1654-P), was informed by codes previously developed by RAND for reporting post-operative care. RAND also conducted testing to assess the practicality and accuracy of these proposed G-codes in real-world clinical settings. The RAND report, “Testing New Codes to Capture Post-Operative Care” (2017), provides insights into the findings of this testing phase.
CMS references to Final Rules concerning 010 and 090 Global days codes involved with post-operative data collection are mandated by Section 1848(c)(8)(B) of the Social Security Act. Detailed information regarding this data collection effort can be found in the CY 2017 PFS final rule (CMS-1654-F, pages 80209-80225). Additionally, CMS collaborated with RAND to conduct surveys to gather supplementary data on pre- and post-operative services, further detailed on pages 80222-80224 of the same final rule.
In conclusion, accurate coding of post-operative care, particularly for complex neurosurgical procedures like craniotomies, is paramount for ensuring appropriate reimbursement within the global surgical package framework. CMS’s ongoing data collection efforts and resources, including code lists and RAND reports, are vital tools for healthcare providers seeking to optimize their coding practices and achieve payment accuracy. For further inquiries, contact [email protected].
