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CMS Releases 2015 Medicare Physician Fee Schedule Final Rule:

Update from the ACS Washington Office

The Centers for Medicare & Medicaid Services (CMS) released the 2015 Medicare Physician Fee Schedule final rule, which included a provision to transition all 10- and 90-day global codes to 0-day global codes.  The transition for 10-day global codes would begin in 2017 and the transition for 90-day global codes would begin in 2018.  CMS has not yet developed a methodology for making this transition.
CMS believes a transition to 0-day global codes would:
  • Increase the accuracy of PFS payment by setting payment rates for individual services based more closely on the typical resources used;
  • Avoid potential duplicative or unwarranted payments when a patient receives post-operative care from a different practitioner;
  • Eliminate disparities between the payment for E/M services in the global periods and those furnished individually;
  • Maintain the same-day policy of including pre- and post-operative services in the 0-day global; and
  • Facilitate availability of more accurate data for new payment models and quality research.

ACS Advocacy to Date

Prior to the release of the Final Rule, ACS submitted a detailed comment letter to CMS stressing that CMS should not move forward with this proposal without a comprehensive analysis of the effect it would have on the provision of surgical care, surgical patients, and the surgeons who care for them.  Given that this is a wide-ranging proposal affecting well over one-third of all CPT codes, we asserted that CMS should delay its implementation until stakeholders have had sufficient time to comment meaningfully.  In the interim, we described and made recommendations on a number of issues that CMS must resolve before moving forward with the proposed policy.  These include:  (1) CMS’ data accuracy concerns; (2) implementation considerations; and (3) unintended or unknown consequences.  ACS also held a conference call with CMS staff to reiterate these concerns and to share the initial results of data analyses that ACS has done to examine the impact of this policy.  Our letter and communications with CMS underscored that, above all, ACS is committed to high quality care of the surgical patient.

ACS Advocacy Moving Forward

ACS will continue to oppose the implementation of this policy unless CMS assures that it will not negatively impact patients and can be implemented in a way that properly accounts for the care that surgeons provide.
In the next few months, ACS will take the following steps:
  • Submit comments to the Final Rule to CMS by the December 31 deadline;
  • Develop and implement a legislative strategy;
  • Continue working with a statistician to conduct a data analysis of the impact of this policy on surgeons;
  • Meet with CMS;
  • Coordinate efforts with the surgical coalition;
  • Discuss at the December GSCRC meeting and at the January HPAG meeting;
  • Coordinate with the AMA, AAMC, MGMA, AHA, and other non-surgical groups; and
  • Update ACS Fellows using special emails, NewsScope, the Bulletin, the Advocate, and the ACS website.