Compliance News:
MACRA, 99024 and Reporting Post-Op Visits to CMS
Department of Justice (DOJ) Updates
99024 – CMS Requires Reporting Post Op Visits
Beginning July 1, 2017, the Centers for Medicare and Medicaid Services (CMS) requires practitioners in the following 9 states to report post-operative visits provided during the global surgical period for specified procedures. CMS states this is to reduce the overall burden and states were randomly selected to be representative with respect to size and geography:
- Florida
- Kentucky
- Louisiana
- Nevada
- New Jersey
- North Dakota
- Ohio
- Oregon
- Rhode Island
Is your provider exempt?
Practices with fewer than 10 practitioners are exempt from required reporting, but are encouraged by CMS to report if feasible.
Although reporting is required for global procedures furnished on or after July 1, 2017, CMS encourages all practitioners to begin reporting as soon as possible.
Section 1848(c)(8)(B) of the Social Security Act requires CMS to collect data to use in valuing global surgical services.
November 15, 2016 Federal Register – Final Rule.
https://www.gpo.gov/fdsys/pkg/FR-2016-11-15/pdf/2016-26668.pdf
Applicable Codes Where 99024 Visits are Required
The 2017 Physician Fee Schedule Final Rule requires some practitioners to report on post-operative visits furnished during global periods using CPT code 99024. The Final Rule specifies that reporting will be required only for post-operative visits related to procedure codes reported annually by more than 100 practitioners and that are either reported more than 10,000 times or have allowed charges in excess of $10 million annually. The Final Rule further specifies that CMS will use CY 2014 claims data to determine the specific codes for which reporting is required.
Applicable post-operative visits can occur in all sites of care including, but not limited to, ICU, outpatient clinic, or skilled nursing facility.
Relevant telehealth visits should also be reported if the patient is located at an eligible originating site.
IMPORTANT RESOURCES
The list of approximately 290 codes for which such reporting is required beginning July 1, 2017 can be downloaded in a zip file from the CMS web site.
https://www.cms.gov/medicare/medicare-fee-for-service-payment/physicianfeesched/global-surgery-data-collection-.html (scroll down to the bottom of the web page)
Review the April 25, 2017 CMS Power Point which provides further billing instructions and clarifications regarding Teaching Physicians and additional links to resources.
To attend the June 14, 2017 Live Webinar: Unraveling CMS’s Quality Payment Program (QPP) A Practical Approach to Successful Implementation of the MACRA Law hosted by the American Institute of Healthcare Compliance.
http://www.aihc-assn.org/Portals/3/MacraWebinar_June.InfoPkt.pdf
American Institute of Healthcare Compliance (AIHC)
Centers for Medicare & Medicaid Services (CMS), HHS.
