Everything You Ever Wanted to Know About the Global Surgical Package: Coding and Billing for the GSP

If you do the professional fee (pro-fee) coding or billing for surgeries, you know that the rules surrounding the Global Surgical Package (GSP) are many and can be complex. CMS just published a new fact sheet on the GSP and it’s a great recap for coders and billers.

The global surgical package, also called global surgery, includes all necessary services normally furnished by a surgeon before, during, and after a procedure. Medicare payment for the surgical procedure includes the pre-operative, intra-operative and post-operative services routinely performed by the surgeon or by members of the same group with the same specialty. Physicians in the same group practice who are in the same specialty must bill and be paid as though they were a single physician.

Is the global surgery payment restricted to hospital inpatient settings?

Global surgery applies in any setting, including an inpatient hospital, outpatient hospital, Ambulatory Surgical Center (ASC), and physician’s office. Visits to a patient in an intensive care or critical care unit are also included in the global surgical package if made by the surgeon.

How is Global Surgery classified?

There are three types of global surgical packages based on the number of post-operative days.

Zero Day Post-operative Period (endoscopies and some minor procedures)

• No pre-operative period • No post-operative days
• Visit on day of procedure is generally not payable as a separate service

Ten-day Post-operative Period, (other minor procedures)

•  No pre-operative period
•  Visit on day of the procedure is generally not payable as a separate service
•  Total global period is 11 days. Count the day of the surgery and 10 days following the day of the surgery

Ninety-day Post-operative Period (major procedures)

• One day pre-operative included
• Day of the procedure is generally not payable as a separate service
• Total global period is 92 days. Count 1 day before the day of the surgery, the day of surgery, and the 90 days immediately following the day of surgery

Where can I find the post-operative periods for covered surgical procedures?

The Medicare Physician Fee Schedule (MPFS) look- up tool provides information on each procedure code, including the global surgery indicator (available at: http://www.cms.gov/apps/physician-fee-schedule/ overview.aspx). The payment rules for global surgical packages apply to procedure codes with global surgery indicators of 000, 010, 090, and, sometimes, YYY.

• Codes with “000” are endoscopies or some minor surgical procedures (zero day post-operative period).
• Codes with “010” are other minor procedures (10-day post-operative period).
• Codes with “090” are major surgeries (90-day post-operative period)
• Codes with “YYY” are contractor-priced codes, for which contractors determine the global period. The global period for these codes will be 0, 10, or 90 days. Note: not all contractor-priced codes have a “YYY” global surgical indicator. Sometimes the global period is specified as 000, 010, or 090.

While codes with “ZZZ” are surgical codes, they are add-on codes that are always billed with another service. There is no post-operative work included in the MPFS payment for the “ZZZ” codes. Payment is made for both the primary and the add-on codes, and the global period assigned is applied to the primary code.

What services are included in the global surgery payment?

The following services are included in the global surgery payment when furnished by the physician who furnishes the surgery:

• Pre-operative visits after the decision is made to operate. For major procedures, this includes pre-operative visits the day before the day of surgery. For minor procedures, this includes pre-operative visits the day of surgery;

• Intra-operative services that are normally a usual and necessary part of a surgical procedure.

• All additional medical or surgical services required of the surgeon during the post-operative period of the surgery because of complications, which do not require additional trips to the operating room;

• Follow-up visits during the post-operative period of the surgery that are related to recovery from the surgery;

• Post-surgical pain management by the surgeon;

• Supplies, except for those identified as exclusions; and

• Miscellaneous services, such as dressing changes, local incision care, removal of operative pack, removal of cutaneous sutures and staples, lines, wires, tubes, drains, casts, and splints; insertion, irrigation and removal of urinary catheters, routine peripheral intravenous lines, nasogastric and rectal tubes; and changes and removal of tracheostomy tubes.

What services are not included in the global surgery payment?

• Treatment for post-operative complications requiring a return trip to the Operating Room (OR). An OR, for this purpose, is defined as a place of service specifically equipped and staffed for the sole purpose of performing procedures. The term includes a cardiac catheterization suite, a laser suite, and an endoscopy suite. It does not include a patient’s room, a minor treatment room, a recovery room, or an intensive care unit (unless the patient’s condition was so critical there would be insufficient time for transportation to an OR);

• If a less extensive procedure fails, and a more extensive procedure is required, the second procedure is payable separately;

• Immunosuppressive therapy for organ transplants;

• Critical care services (Current Procedural Terminology (CPT) codes 99291 and 99292) unrelated to the surgery where a seriously injured or burned patient is critically ill and requires constant attendance of the physician.

How are minor procedures and endoscopies handled?

Minor procedures and endoscopies have post-operative periods of 10 days or zero days (indicated by 010 or 000, respectively). For 10-day post-operative period procedures, Medicare does not allow separate payment for post-operative visits or services within 10 days of the surgery that are related to recovery from the procedure. If a diagnostic biopsy with a 10-day global period precedes a major surgery on the same day or in the 10-day period, the major surgery is payable separately. Services by other physicians are generally not included in the global fee for minor procedures.

For zero day post-operative period procedures,  operative visits beyond the day of the procedure are not  included in the payment amount for the surgery. Post- procedure is payable separately.

Physicians Who Furnish the Entire Global Package

Physicians who furnish the surgery and furnish all of the usual pre-and post-operative work may bill for the global package by entering the appropriate CPT code for the surgical procedure only. Separate billing is not allowed for visits or other services that are included in the global package.

When different physicians in a group practice participate in the care of the patient, the group practice bills for the entire global package if the physicians reassign benefits to the group. The physician who performs the surgery is reported as the performing physician.

Physicians Who Furnish Part of a Global Surgical Package

More than one physician may furnish services included in the global surgical package. It may be the case that the physician who performs the surgical procedure does not furnish the follow-up care. Payment for the post-operative, post-discharge care is split among two or more physicians where the physicians agree on the transfer of care.

When more than one physician furnishes services that are included in the global surgical package, the sum of the amount approved for all physicians may not exceed what would have been paid if a single physician provided all services, except where stated policies allow for higher payment. For instance, when the surgeon furnishes only the surgery and a physician other than the surgeon furnishes pre-operative and post-operative inpatient care, resulting in a combined payment that is higher than the global allowed amount.

The surgeon and the physician furnishing the post-operative care must keep a copy of the written transfer agreement in the beneficiary’s medical record. Where a transfer of care does not occur, the services of another physician may either be paid separately or denied for medical necessity reasons, depending on the circumstances of the case.

Split global-care billing does not apply to procedure codes with a zero day post-operative period.ite.

Using Modifiers “-54” and “-55”

Where physicians agree on the transfer of care during the global period, services will be distinguished by the use of the appropriate modifier:

• Surgical care only (modifier “-54”); or
• Post-operative management only (modifier “-55”).

For global surgery services billed with modifiers “-54” or “-55,” the same CPT code must be billed. The same date of service and surgical procedure code should be reported on the bill for the surgical care only and post- operative care only. The date of service is the date the surgical procedure was furnished.

• Modifier “-54” indicates that the surgeon is relinquishing all or part of the post-operative care to a physician.
• Modifier “-54” does not apply to assistant at surgery services.
• Modifier “-54” does not apply to an ASC’s facility fees.
• The physician, other than the surgeon, who furnishes post- operative management services, bills with modifier “-55.”
• Use modifier “-55” with the CPT code for global periods of 10 or 90 days.
• Report the date of surgery as the date of service and indicate the date care was relinquished or assumed. Physicians must keep copies of the written transfer agreement in beneficiary’s medical record.
• The receiving physician must provide at least one service before billing for any part of the post- operative care.
• This modifier is not appropriate for assistant at surgery services or for ASC’s facility fees.

Exceptions to the Use of Modifiers “-54” and “-55”

• Where a transfer of care does not occur, occasional post-discharge services of a physician other than the surgeon are reported by use of the appropriate level E/M code. No modifiers are necessary on the claim.
• Physicians who provide follow-up services for minor procedures performed in emergency departments bill the appropriate level of E/M code, without a modifier.
• If the services of a physician other than the surgeon are required during a post-operative period for an underlying condition or medical complication, the other physician reports the appropriate level E/M code. No modifiers are necessary on the claim. An example is a cardiologist who manages underlying cardiovascular conditions of a patient.

Preoperative Billing

E/M Service Resulting in the Initial Decision to Perform Surgery

E/M services on the day before major surgery or on the day of major surgery that result in the initial decision to perform the surgery are not included in the global surgery payment for the major surgery and, therefore, may be billed and paid separately.

In addition to the E/M code, modifier “-57” (Decision for surgery) is used to identify a visit that results in the initial decision to perform surgery.

The modifier “-57” is not used with minor surgeries because the global period for minor surgeries does not include the day prior to the surgery. Where the decision to perform the minor procedure is typically done immediately before the service, it is considered a routine pre-operative service and a visit or consultation is not billed in addition to the procedure. Carriers/MACs may not pay for an E/M service billed with the modifier “-57” if it was provided on the day of or the day before a procedure with a 0 or 10 day global surgical period.

Day of Procedure Billing

Significant, Separately Identifiable E/M Service by the Same Physician on the Same Day of the Procedure

Modifier “-25” (Significant, separately identifiable E/M service by the same physician on the same day of the procedure), indicates that the patient’s condition required a significant, separately identifiable E/M service beyond the usual pre-operative and post- operative care associated with the procedure or service.

• Use modifier “-25” with the appropriate level of E/M service.
• Use modifiers “-24” (Unrelated E/M service by the same physician during a post-operative period) and “-25” when a significant, separately identifiable E/M service on the day of a procedure falls within the post-operative period of another unrelated, procedure.
• Different diagnoses are not required for reporting the E/M service on the same date as the procedure or other service. Both the medically-necessary E/M service and the procedure must be appropriately and sufficiently documented by the physician or qualified nonphysician practitioner in the patient’s medical record to support the claim for these services, even though the documentation is not required to be submitted with the claim.

Claims for Multiple Surgeries

Multiple surgeries are separate procedures performed by a single physician or physicians in the same group practice on the same patient at the same operative session or on the same day for which separate payment may be allowed. Co-surgeons, surgical teams, or assistants at surgery may participate in performing multiple surgeries on the same patient on the same day.

Surgeries subject to the multiple surgery rules have an indicator of “2” in the Physician Fee Schedule look-up tool. The multiple procedure payment reduction will be applied based on the MPFS approved amount and not on the submitted amount from the providers. The major surgery may or may not be the one with the larger submitted amount.

Multiple surgeries are distinguished from procedures that are components of or incidental to a primary procedure. These intra-operative services, incidental surgeries, or components of more major surgeries are not separately billable.

There may be instances in which two or more physicians each perform distinctly different, unrelated surgeries on the same patient on the same day (for example, in some multiple trauma cases). When this occurs, the payment adjustment rules for multiple surgeries may not be appropriate.

Claims for Co-Surgeons and Team Surgeons

Under some circumstances, the individual skills of two or more surgeons are required to perform surgery on the same patient during the same operative session. This may be required because of the complex nature of the procedures and/or the patient’s condition. In these cases, the additional physicians are not acting as assistants at surgery.

The following billing procedures apply when billing for a surgical procedure or procedures that require the use of two surgeons or a team of surgeons:

• If two surgeons (each in a different specialty) are required to perform a specific procedure, each surgeon bills for the procedure with a modifier “-62” (Two surgeons). Co-surgery also refers to surgical procedures involving two surgeons performing the parts of the procedure simultaneously, i.e., heart transplant or bilateral knee replacements. Certain services that require documentation of medical necessity for two surgeons are identified in the MPFS look-up tool.

• If a team of surgeons (more than 2 surgeons of different specialties) is required to perform a specific procedure, each surgeon bills for the procedure with a modifier “-66” (Surgical team). Certain services, as identified in the MPFS look- up tool, submitted with modifier “-66” must be sufficiently documented to establish that a team was medically necessary. All claims for team surgeons must contain sufficient information to allow pricing “by report.”

• If surgeons of different specialties are each performing a different procedure (with specific CPT codes), neither co-surgery nor multiple surgery rules apply (even if the procedures are performed through the same incision). If one of the surgeons performs multiple procedures, the procedure rules apply to that surgeon’s services.

Post-operative Period Billing

Unrelated Procedure or Service or E/M Service by the Same Physician During a Post-operative Period

Two modifiers are used to simplify billing for visits and other procedures that are furnished during the post-operative period of a surgical procedure, but not included in the payment for surgical procedure.

• Modifier “-79” (Unrelated procedure or service by the same physician during a post-operative period). The physician may need to indicate that a procedure or service furnished during a post- operative period was unrelated to the original procedure. A new post-operative period begins when the unrelated procedure is billed.

•  Modifier “-24” (Unrelated E/M service by the same physician during a post-operative period). The physician may need to indicate that an E/M service was furnished during the post-operative period of an unrelated procedure. An E/M service billed with modifier “-24” must be accompanied by documentation that supports that the service is not related to the post-operative care of the procedure.

Return to the OR for a Related Procedure during the Post-Operative Period

When treatment for complications requires a return trip to the OR, physicians bill the CPT code that describes the procedure(s) performed during the return trip. If no such code exists, use the unspecified procedure code in the correct series, i.e., CPT code 47999 or 64999. The procedure code for the original surgery identical procedure is repeated. In addition to the CPT code, physicians report modifier “-78” (Unplanned return to the operating or procedure room by the same physician following initial procedure for a related procedure during the post-operative period).

The physician may also need to indicate that another procedure was performed during the post-operative period of the initial procedure. When this subsequent procedure is related to the first procedure, and requires the use of the operating room, this circumstance may be reported by adding the modifier “-78” to the related procedure.

Staged or Related Procedure or Service by the Same Physician During the Post-operative Period

Modifier “-58” (Staged or related procedure or service by the same physician during the post-operative period) was established to facilitate billing of staged or related surgical procedures done during the post-operative period of the first procedure. Modifier “-58” indicates that the performance of a procedure or service during the post-operative period was:

• Planned prospectively or at the time of the original procedure;
• More extensive than the original procedure; or
• For therapy following a diagnostic surgical procedure.

Modifier “-58” may be reported with the staged procedure’s CPT code. A new post-operative period begins when the next procedure in the series is billed.

In addition to the CPT code, physicians report modifier “-78” (Unplanned return to the operating or procedure room by the same physician following initial procedure for a related procedure during the post-operative period).

The physician may also need to indicate that another procedure was performed during the post-operative period of the initial procedure. When this subsequent procedure is related to the first procedure, and requires the use of the operating room, this circumstance may be reported by adding the modifier “-78” to the related procedure.

Critical Care

Critical care services furnished during a global surgical period for a seriously injured or burned patient are not considered related to a surgical procedure and may be paid separately under the following circumstances.

Pre-operative and post-operative critical care may be paid in addition to a global fee if:

• The patient is critically ill and requires the constant attendance of the physician; and
• The critical care is above and beyond, and, in most instances, unrelated to the specific anatomic injury or general surgical procedure performed.

Such patients are potentially unstable or have conditions that could pose a significant threat to life or risk of prolonged impairment.

In order for these services to be paid, two reporting requirements must be met:

• CPT codes 99291/99292 and modifier “-25” for pre-operative care or “-24” for post-operative care must be used; and
• Documentation that the critical care was unrelated to the specific anatomic injury or general surgical procedure performed must be submitted. An ICD-10 code for a disease or separate injury which clearly indicates that the critical care was unrelated to the surgery is acceptable documentation.

Health Professional Shortage Area (HPSA) Payments for Services Which are Subject to the Global Surgery Rules

HPSA bonus payments may be made for global surgeries when the services are provided in HPSAs. The following are guidelines for the appropriate billing procedures:

• If the entire global package is provided in a HPSA, physicians should bill for the appropriate global surgical code with the applicable HPSA modifier.
•  If only a portion of the global package is provided in a HPSA, the physician should bill using a HPSA modifier for the portion which is provided in the HPSA.

Billing Wrong Surgical or Other Invasive Procedures Performed on a Patient, Surgical or Other Invasive Procedures Performed on the Wrong Body Part, and Surgical or Other Invasive Procedures Performed on the Wrong Patient

Providers are required to append one of the following applicable Healthcare Common Procedure Coding System modifiers to all lines related to the erroneous surgery or surgeries:

• PA: Surgery Wrong Body Part
• PB: Surgery Wrong Patient; or
• PC: Wrong Surgery on Patient.

For more information, refer to the “National Coverage Determination Manual,” Chapter 1, Part 2, Section 140.6 “Wrong Surgical or Other Invasive Procedure Performed on a Patient,” 140.7 “Surgical or Other Invasive Procedure Performed on the Wrong Body Part,” and 140.8 “Surgical or Other Invasive Procedure Performed on the Wrong Patient” available at http://www.cms.gov/manuals/downloads/ ncd103c1_Part2.pdf on the CMS website.

References:

• Payment rates and indicators (including the global surgery indicator) can be found in the MPFS look-up tool available at http://www.cms.gov/apps/physician-fee-schedule/ overview.aspx on the CMS website.
•  For more information, refer to The Payment System Fact Sheet “Medicare Physician Fee Schedule” (MPFS), which provides a brief overview of the MPFS, available at http://www.cms.gov/MLNProducts/downloads/ MedcrePhysFeeSchedfctsht.pdf on the CMS website.
• For more information on Billing Wrong Surgical or Other Invasive Procedures, refer to the “Medicare Claims Processing Manual” (Chapter 32, Section 230 – Billing Requirements for Special Services) available at http:// www.cms.gov/manuals/downloads/clm104c32.pdf on the CMS website.
•  “Medicare Claims Processing Manual” (Chapter 12, Section 40.2 – Physicians/Nonphysician Practitioners) available at http://www.cms.gov/manuals/downloads/clm104c12.pdf on the CMS website.