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CMS Should Confirm It Is Receiving Medicare Postoperative Visit Data on Global Surgeries When Reporting Is Required

Issued on  | Posted on  | Report number: A-05-20-00027

Why OIG Did This Audit

  • Under Medicare’s global surgery policy, CMS bundles into a single payment those services normally furnished by a practitioner before, during, and after a procedure, such as postoperative visits.
  • To determine the payment (i.e., the global surgery fee), one element CMS considers is the number of postoperative visits for a typical patient. As part of the Medicare Access and CHIP Reauthorization Act of 2015, Congress mandated that CMS gather information to assist in improving the accuracy of global surgery valuation (i.e., the fees). CMS began to collect this claim information from practitioners, and we audited a sample of the global surgeries. The results of that audit were reported in audit report A-05-20-00021.
  • This audit looks at global surgeries without any reported postoperative visits, that were not covered by the congressionally mandated audit. It assessed whether the medical record indicated there were postoperative visits and whether the global surgery fee valuation was accurate.

What OIG Found

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.

What OIG Recommends

We recommend that CMS confirm it is receiving Medicare postoperative visit data from practitioners that it expected would be reporting postoperative visits and notify any practitioners if no postoperative visits are reported.

CMS concurred with our recommendation.

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

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