As we have reported, in the 2020 Medicare Physician Fee Schedule proposed rule, CMS is proposing to increase the value of standalone E/M office visits beginning in 2021. However, the agency did not propose to increase the value of post-operative E/M visits that are bundled into 10- and 90-day global surgery codes. ASCRS recently joined with the American Medical Association (AMA) and the medical community to meet with CMS and recommend that the agency increase the value of the post-operative E/M visits in the global period when it finalizes the fee schedule rule in November. In addition, as we previously reported, ASCRS has joined with the AMA and the surgical community in a letter to CMS reiterating our call to increase the post-operative values. ASCRS will submit comprehensive comments on the proposed rule, including this issue, and will also recommend that CMS increase the value of comprehensive eye exam codes, which are based on E/M values.
In our advocacy to CMS, we have noted that its proposal disrupts the relativity of the physician fee schedule and runs afoul of the statute requiring that Medicare reimburse physicians for the same services furnished, regardless of the specialty. Global surgery codes are structured to include not only the surgery itself, but the E/M visits furnished in the post-operative period. Since these post-operative visits require the same work, practice expense, and malpractice costs as standalone E/M services, they should be paid at the same rate.
ASCRS ASOA members are encouraged to lend their voices to the effort to increase the value of post-operative E/M services in 10- and 90-day global codes and the eye codes by submitting a comment on the proposed rule before the comment period closes on September 27, 2019.
ASCRS ASOA has provided a sample comment to assist members. Please feel free to use this sample and update with your personal information:
I am (an ophthalmologist/a practice administrator) in (include location) who sees a high volume of Medicare Part B patients. I urge CMS to modify its proposed policy that would not increase the value of post-operative E/M services included in global surgery codes. I recommend that in the final rule, CMS increase the value of these E/M services to the same level as the recently re-valued standalone office visit E/M services beginning in 2021. Global surgery codes are valued to include office visit E/M services. For example, cataract surgery includes three post-operative visits—two level 2 and one level 3—in the global bundle. The work and practice expense required to furnish post-operative office visits is the same as if I were to see a patient for an E/M visit not related to post-operative care, and therefore, the payment should be the same. In addition, CMS should also increase the value of comprehensive eye exam codes (CPT codes 92002, 92004, 92012, 92014), whose value are based on E/M office visit codes.
If you have additional questions, please contact Allison Madson, manager of regulatory affairs, at email@example.com or 703-591-2220.