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Series: Review of Post-Operative Services Provided in the Global Surgery Period

Announced on  | Last Modified on  | Series Number: W-00-24-35810
Status
Completed
Agency
Centers for Medicare and Medicaid Services

OBJECTIVE

Section 523 of Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) requires CMS to collect data on post-operative services included in global surgeries and requires OIG to audit and verify a sample of the data collected. We will review a sample of global surgeries to determine the number of post-operative services documented in the medical records and compare it to the number of post-operative services reported in the data collected by CMS. We will verify the accuracy of the number of post-operative visits reported to CMS by physicians and determine whether global surgery fees reflected the actual number of post-operative services that physicians provided to beneficiaries during the global surgery period.

There are 2 projects in this series.

COMPLETED PROJECTS IN THIS SERIES (2)

Postoperative Services Provided During the Global Period

Project A-05-20-00027 • Completed on August 26, 2025

Post Operative Services Provided in the Global Period

Project A-05-20-00021 • Completed on June 26, 2025

TIMELINE

  • February 10, 2020
    Series Number W-00-24-35810 Assigned
  • February 10, 2020
    Project Announced

    Post Operative Services Provided in the Global Period - A-05-20-00021

  • March 3, 2020
    Project Announced

    Postoperative Services Provided During the Global Period - A-05-20-00027

  • June 26, 2025
    Project Complete - A-05-20-00021

    Post Operative Services Provided in the Global Period has been marked as complete. This audit resulted in 5 recommendations.

  • August 26, 2025
    Project Complete - A-05-20-00027

    Postoperative Services Provided During the Global Period has been marked as complete. This audit resulted in 1 recommendation.

  • August 26, 2025
    Series Complete

    Review of Post-Operative Services Provided in the Global Surgery Period has been marked as complete.

2 REPORT PUBLISHED

CMS Should Improve Its Methodology for Collecting Medicare Postoperative Visit Data on Global Surgeries (A-05-20-00021)

Although practitioners are not required to provide Medicare patients the number of postoperative visits that CMS considered in valuing the global surgery fee, based on our sample results, we discovered that overall, fewer visits are provided than are considered in the valuation. We estimated that Medicare paid a net $5.7 million more and that Medicare patients paid a net $1.7 million more than would have been paid if global surgery fees reflected actual utilization of postoperative visits.

Postoperative visit data CMS gathered for 45 of 105 sampled global surgeries were inaccurate and cannot assist in improving global surgery valuation as Congress intended.

Improving global surgery valuation is still needed, as we identified that the fees for 91 of 105 sampled global surgeries did not reflect the number of postoperative visits provided.

25-A-05-075.01 to CMS - Open Unimplemented
Update expected on 04/30/2026
We recommend that the Centers for Medicare & Medicaid Services educate practitioners and encourage the practitioners to educate the practices' staff on its data collection policy requirements for inpatient and outpatient settings and direct the MACs to educate individual practitioners on reporting requirements for postoperative visits after global surgeries.

25-A-05-075.02 to CMS - Open Unimplemented
Update expected on 12/25/2025
We recommend that the Centers for Medicare & Medicaid Services establish detailed requirements for documenting postoperative visits provided in all settings in the medical records.

25-A-05-075.03 to CMS - Open Unimplemented
Update expected on 12/25/2025
We recommend that the Centers for Medicare & Medicaid Services take one of the following steps to improve reporting of postoperative visits: establish and maintain a mechanism to identify practitioners that are required to report their postoperative visits and notify them of the reporting requirement; require all practitioners to report postoperative visits; or revise its requirements to clarify which practitioners are required to report.

25-A-05-075.04 to CMS - Open Unimplemented
Update expected on 12/25/2025
We recommend that the Centers for Medicare & Medicaid Services improve its methodology for data collection to identify the relevant global surgery on postoperative visit claims and to obtain data on Medicare postoperative visits during hospital stays.

25-A-05-075.05 to CMS - Open Unimplemented
Update expected on 12/25/2025
We recommend that the Centers for Medicare & Medicaid Services update its valuation of the global surgery fees to reflect the number of postoperative visits actually being provided to Medicare patients, which could have reduced payments for the global surgeries in our sampling frame by an estimated $5,723,292 for Medicare and an estimated $1,666,631 for Medicare patients.

View in Recommendation Tracker

CMS Should Confirm It Is Receiving Medicare Postoperative Visit Data on Global Surgeries When Reporting Is Required (A-05-20-00027)

Although practitioners are not required to provide Medicare patients the number of postoperative visits that CMS considered in valuing the global surgery fee, we discovered that fewer visits are provided than are considered in the valuation. Based on our sample results, we estimated that Medicare paid $7.8 million more and that Medicare patients paid $4.8 million more than would have been paid if global surgery fees reflected actual utilization of postoperative visits.

Postoperative visit data gathered by CMS for 9 of 105 sampled global surgeries were inaccurate and cannot assist in improving global surgery valuation as Congress intended. For 98 of 105 sampled global surgeries, we identified that the fees did not reflect the number of postoperative visits provided. Based on these results, improving global surgery valuation is still needed.

25-A-05-109.01 to CMS - Open Unimplemented
Update expected on 02/25/2026
We recommend that the Centers for Medicare & Medicaid Services confirm it is receiving CPT code 99024 data from practitioners that it expected would be reporting postoperative visits and notify any practitioners if no postoperative visits are reported.

View in Recommendation Tracker
Work Plan Type
Office of Audit Services
HHS Agencies
Centers for Medicare and Medicaid Services
Issue Areas
Financial Stewardship
Target Groups
-
Financial Groups
Medicare A Medicare B