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Medicare: Proposed and Final Rules

Medicare Billing Update: CMS Moving Forward With Plan to Eliminate 10- and 90-day Global Surgical Packages

Reimbursement for surgical procedures has historically included payment for all services and supplies that are routine and necessary to perform the procedure. Pre- and post-operative components of the surgical package were not eligible for separate reimbursement and were denied if billed within the global period of the surgical procedure.

Over the past several years, CMS has found that many global surgery package CPT codes billed to Medicare beneficiaries are actually paying for more follow-up care than is typically furnished to the patient. Despite strong opposition from ASPS, the AMA and other surgical specialty societies, CMS is moving forward with its plan, first outlined in the 2015 Proposed Rule, to eliminate all 10- and 90-day global surgical packages.

For 2015, the agency will retain the global period concept for surgical services, but over time, convert the 10 and 90 day codes to 0 day global codes, in 2017 and 2018 respectively.

ASPS is working with the AMA, and the Alliance of Specialty Medicine to educate lawmakers on the unintended consequences of these changes, and to offer alternatives that can track utilization without increasing the administrative burden for providers.

Plastic surgeons are encouraged to comment directly to CMS on the impact of this Final Rule.

Medicare Proposed Updates & ASPS Comments

Each year, in July, the Center for Medicare & Medicaid Services (CMS) releases proposed updates to the next year's Medicare fee schedules.

Many of the payment policies proposed by CMS will have a direct impact on providers’ day-to-day operations. The public is given the opportunity to comment during the proposed rule stage. Links to the proposed rules as well as comments submitted on behalf of ASPS, are included below.

Unless public comment and/or Congressional action prompts changes in the draft language, the proposed changes are confirmed in a Final Rule, which is generally published in mid-November. Although the proposals are technically finalized in the final rules, ASPS once again submits comments, in response. All changes published in the final rule are intended to take effect on January 1 of the next calendar year, unless otherwise specified.

All comments are vetted internally, by the appropriate ASPS committees and are finalized and submitted on behalf of the ASPS president.

Medicare Physician Fee Schedule (MPFS) - Proposed changes to Medicare Part B (physician office) reimbursement

Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs (HOPPS) – Proposed changes to Hospital outpatient & ambulatory surgical center reimbursement