CMS released in November an improved policy on global codes data collection. The changes will affect any surgeon or doctor who provides 10- and 90-day global code services, regardless of the setting.
The changes to the claims-based data process might be burdensome for some physicians, but it’s an improvement over the original proposal, says Vinita Ollapally, JD, regulatory affairs manager for The American College of Surgeons, headquartered in Chicago. Ollapally is based in Washington, DC.
“Originally, CMS proposed a policy that would have been incredibly burdensome for anyone performing these services,” Ollapally says. “What CMS has done is to change the policy quite substantially in the final rule to make it easier for physicians to comply.”
The American College of Surgeons pushed very hard, convening a global coalition of all stakeholders to seek a change to the initial proposal, she says. The effort succeeded.
“We pulled together this coalition, made recommendations, and we feel like CMS listened and made adjustments that are going to make this much easier for physicians to comply,” Ollapally says. “There also is a higher likelihood of CMS collecting data that’s usable.”
The organization will keep an eye on the policy as it moves forward, she adds.
CMS had intended to collect data from every single physician who provides 10- or 90-day global code services. But this approach was not in line with the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which requires only a representative number of physicians to submit data, Ollapally says.
In the revised policy, CMS requires physicians who provide 10- or 90-day global codes in only nine states to provide data, she says.
“We consider that a big win, and we’re very happy with it,” Ollapally says. “CMS is interpreting this policy in line with the MACRA policy.”
In addition, CMS has narrowed the requirements even further by only requiring physicians who are in large practices of 10 or more practitioners to provide data, she says.
“They’re exempting small practices that may not have the ability to take on this new compliance requirement, so that’s something we’re very happy with,” Ollapally says.
Also, CMS is not requiring that every single 10- and 90-day global code service be reported. The agency focuses on specific codes related to high volume or high Medicare expenditures. These types of codes have to be provided by at least 100 physicians nationwide, she explains.
“The point is they’re trying to focus on the codes [and] narrow it down to the codes that provide the most relevant data, instead of requiring all data,” Ollapally says. “It reduces the burden on physicians a little bit.”
CMS soon will list which codes will be collected. The nine states affected by the initial data reporting include Florida, Kentucky, Louisiana, Nevada, New Jersey, North Dakota, Ohio, Oregon, and Rhode Island.
“CMS divided all of the states into four categories, based on how many Medicare beneficiaries there are per state, and they tried to select states from all four of those categories,” Ollapally says. “These are based on the number of Medicare beneficiaries in the states, and they tried to get states representing all nine census regions.”
Another positive change is that the requirement’s start date has been pushed back from Jan. 1, 2017, to July 1, 2017.
“It is six months later to give physicians time to understand what was required for reporting purposes,” Ollapally says.
The American College of Surgeons also is pleased that CMS did away with its original requirement that data collection use G codes in which physicians would have to capture data in 10-minute increments. “That would have been an incredible burden on physicians because they’re not used to carrying around a stopwatch to know when they start and stop,” she says. “The G-code proposal was not aligned with clinical workflow.”
Also, the G-code proposal likely would not have produced accurate data, she says.
Instead, physicians report only one 99024 code, which is the CBT code for capturing post-op visits within the global code, Ollapally says. “That’s going to be so much easier.”
Overall, CMS has answered the organization’s chief concerns about the policy. CMS also is expected to survey practitioners to obtain even more detailed information.
Meanwhile, The American College of Surgeons will talk with members about how this policy will be implemented.
“We’ll want to know more about what the codes are,” Ollapally says. “This still will be a burden, an extra thing that some practices are going to have to do.”