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• The recommended codes attempt to balance the need for a simple system but one that adequately captures the heterogeneity of post-operative care.
• The majority of post-operative visits are straightforward; therefore, the key is identifying the smaller number of complex visits.
• Devising a simple system to facilitate reporting is important to minimize the reporting burden for individuals performing surgical procedures.
• This report considers the advantages and disadvantages of four approaches for capturing post-operative care through claims: site of care; evaluation and management (E&M) visits; scope of care; and time. E&M is familiar to proceduralists, but the codes are a poor fit for the unique circumstances of post-operative visits and could lead to considerable documentation burden.
• No single framework (site of care, time, or scope of care) is ideal for capturing post-operative visits. The expert panel was most enthusiastic about a set of codes that used elements of all these frameworks.
• Nonpayment codes are a poor mechanism to capture practice expenses, which should be captured by other means.

The Centers for Medicare & Medicaid Services (CMS) uses a fee schedule to pay physicians and nonphysician practitioners for their professional services. For many surgeries and other types of procedures, Medicare's payment for the procedure includes post-operative visits delivered during a global period of ten or 90 days anchored on the surgery date. The Medicare Access and CHIP Reauthorization Act of 2015 requires CMS gather the necessary data to appropriately value post-operative care. The law requires CMS to collect data on the "number and level" of visits in the global period from a representative sample of physicians beginning January 1, 2017. Congress suggested, but does not require, that the data be collected through claims.

CMS asked the RAND Corporation to provide recommendations on how to best collect the number and level of post-operative visits through the use of nonpayment claims. To do so, RAND first gathered input from individuals performing surgical procedures on the range of post-operative care provided during the global period. RAND consulted with an expert panel on how to categorize the care into codes that capture the major differences in the breadth and intensity of post-operative care across care settings.

This report provides recommendations for a set of nonpayment codes that combine visit times with the complexity of services, for both inpatient and office-based services. The recommended codes attempt to balance the need for a simple and straightforward system with the demand for a set of codes to capture the granularity and heterogeneity associated with post-operative care delivery.

• Chapter One

  Introduction

• Chapter Two

  Overview of Current Payment Policy for Post-Operative Services in the Global Period

• Chapter Three

  Interviews on Post-Operative Care

• Chapter Four

  Challenges Identified During Interviews and Expert Panel in Capturing Post-Operative Care via Codes

• Chapter Five

  Options for Capturing Post-Operative Care

• Chapter Six

  Recommendations for Capturing Post-Operative Care

• Chapter Seven

  Summary and Next Steps