2027 - CMS proposes 50% pay cut for 25 modifier visits

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Accounting for Overlap Between Stand-Alone E/M Visits and Global Periods

For CY 2027, we are proposing to reduce payment when a separately identifiable office/outpatient evaluation and management (E/M) visit is furnished by the same physician (or a physician in the same practice) on the same day as a 0-, 10-, or 90-day global procedure. The most expensive service (either surgical or E/M visit) would be paid at 100% and all other surgical procedure(s) or E/M visit(s) furnished on the same day would be paid at 50%.

This proposed policy is like a proposal in the CY 2019 PFS proposed rule, made in the context of a broader proposal that would have modified the payment structure of E/M visits. While we did not finalize the proposal at that time, we noted that we continued to believe that there are efficiencies when the same physician (or a physician in the same group practice) provides an E/M service for the same patient in conjunction with a procedure with a global period and that we are likely duplicating payment under the current payment methodology. The current proposal would address that overvaluation.

*This was apparently previously proposed in 2019 but was not implemented.
 
I remember when they first proposed that rule change (along with the podiatry specific e/m codes). It definitely creates an interesting workflow problem when pts have two problems on the same day. Do you do double the work for half the pay or reappoint for full price at the cost of an appointment slot?
 
I remember when they first proposed that rule change (along with the podiatry specific e/m codes). It definitely creates an interesting workflow problem when pts have two problems on the same day. Do you do double the work for half the pay or reappoint for full price at the cost of an appointment slot?
Reappoint.
Medicine side has the same problem with their annuals.

Patient comes in for an annual but also wants 25 other problems addressed.

It is an annual.
Your other complaints are not covered.

Come back later.

Other thing is when insurance limits their coverage to 1 annual + 2 other visits per year.
That's right, so if you get sick or something happens outside of those 2 extra visits- the docs aren't getting reimbursed for the office visit outside of labs or procedures- but these are medicine guys. They aren't doing procedures. So tough titties- send to ER.

Its a s*&^ game that insurance plays.
 
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Do you do double the work for half the pay or reappoint for full price at the cost of an appointment slot?
As someone who does a lot of procedure only visits, reschedule. That’s like half a slot, not a time suck. Get paid your worth.

Tell the patient something to the effect of “sorry, insurance crap where they won’t cover today.” They’re usually conditioned to know the drill. Blame the actual cause.

Two extreme examples. We had an old local doc retire and I picked up some of his patients. Apparently he never billed a visit (to be fair, I’m not sure he ever actually examined anybody), so his patients were extremely unhappy with their exam bills. Hey, no exam, no 25 must have been the thought, but I can’t imagine leaving that level of collections on the table. I’ve also had a patient whose weird insurance doesn’t cover any 25s period try to pay cash same day who then lost it on me when I declined to commit potential insurance fraud.
 
I bill a lot of 99212-25s. This is an outgrowth of pts coming in for their regularly scheduled nail trimmings and their many "oh by the way" complaints. Sometimes it results in a prescription, but most times just counseling. Usually I can generate more per visit than a 99212 on its own and I would rather not schedule a separate visit just to discuss their mild arch pain or their venous insufficiency or their night cramps. But when patients mistake me for their friend and ask me for medical advice, I absolutely bill them for the consultation.
 
We only have -25 on half or two thirds of our visits... I don't see what the big hullabaloo is?

Confused What Did I Do GIF
 
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Accounting for Overlap Between Stand-Alone E/M Visits and Global Periods

For CY 2027, we are proposing to reduce payment when a separately identifiable office/outpatient evaluation and management (E/M) visit is furnished by the same physician (or a physician in the same practice) on the same day as a 0-, 10-, or 90-day global procedure. The most expensive service (either surgical or E/M visit) would be paid at 100% and all other surgical procedure(s) or E/M visit(s) furnished on the same day would be paid at 50%.

This proposed policy is like a proposal in the CY 2019 PFS proposed rule, made in the context of a broader proposal that would have modified the payment structure of E/M visits. While we did not finalize the proposal at that time, we noted that we continued to believe that there are efficiencies when the same physician (or a physician in the same group practice) provides an E/M service for the same patient in conjunction with a procedure with a global period and that we are likely duplicating payment under the current payment methodology. The current proposal would address that overvaluation.

*This was apparently previously proposed in 2019 but was not implemented.
Wait till clawbacks for podiatry excessive billing of E and M plus procedure on majority of patients.!
 
We only have -25 on half or two thirds of our visits... I don't see what the big hullabaloo is?

Confused What Did I Do GIF
Getting a Medicare audit. Major PITA, supposedly more likely with higher percentages. I’m only at 25-33%, but they wanted charts on like 30 patients per doc in our group. Took a couple months, decent bit of staff time. Everything was on the up and up, no claw backs, but zero fun was had other than giving them the finger and knowing they probably won’t come back again any time soon.
 
Getting a Medicare audit. Major PITA, supposedly more likely with higher percentages. I’m only at 25-33%, but they wanted charts on like 30 patients per doc in our group. Took a couple months, decent bit of staff time. Everything was on the up and up, no claw backs, but zero fun was had other than giving them the finger and knowing they probably won’t come back again any time soon.
I know... I was joking. That's a huge revenue hit if the e/m are cut it... also huge time waste (staff/time = $$) if they audit. It's lame.

I've only had audits on a few codes (4 or 5 ingrown proc pts, then single chart for an ankle screw remove in office... was poking out of the guy, but those are place of svc usually OR). Both passed fine, but I haven't been open too long. I probaly get fewer as I see such relatively low volume, though. I have no idea what my -25 percent is... probably a third to half. I just code what I do.

...We will basically end at socialized medicine in one form or another (some docs only take cash pay, some docs - and most hospitals - will take MCR/MCA and see a lot more pts). Private medical insurance plans will probably just become something like eye/dent insurance that covers a portion of the costs for the cash pay docs? The current system that docs, patients, billers, insurances themselves hardly understand has been broken for a long while. The hospital facility fee reimburses are obviously obscene in most cases.
 
This is absolute bull****.

This is like half of our new patient visits. Office visit + nail avulsion. Office visit + plantar wart debridement. Office visit + wound debridement. Private insurance will follow this standard.

Why the **** do I take insurance at this point? These direct care podiatrists are probably onto something and then they never have to pay billers!
 
This is absolute bull****.

This is like half of our new patient visits. Office visit + nail avulsion. Office visit + plantar wart debridement. Office visit + wound debridement. Private insurance will follow this standard.

Why the **** do I take insurance at this point? These direct care podiatrists are probably onto something and then they never have to pay billers!
Where APMA in this crises???!!??
 
This is absolute bull****.

This is like half of our new patient visits. Office visit + nail avulsion. Office visit + plantar wart debridement. Office visit + wound debridement. Private insurance will follow this standard.

Why the **** do I take insurance at this point? These direct care podiatrists are probably onto something and then they never have to pay billers!
Agree... if I were going to remain in the game significantly longer, I would absolutely trend towards cash pay office (probably offer little/no surgery). It'd be powerful to be able to set your own prices... just like attorneys, mechanics, photographers, skilled trades, tech ppl, musicians, etc etc etc can (basically anyone besides docs).

Between the amount of things we have to do yet don't get paid for (work notes/forms, prior auth, Cme, etc etc) and then the work that gets "paid" yet denied or reduced or audited, it's pretty dicey.

Malpractice and EMR costs also seems to rise nearly as fast as tuition does. Staffing and basic utilities/rent and supplies sure don't go down. Reimbursements have not kept pace whatsoever with overhead (this is not unique to podiatry... but it's especially damaging as our ROI was lower all along).

This is the case for most old professions: a lot of red tape, licensing, liability. The difference for medicine is that we can't set our own prices (MCR does).
If we could, you'd see it being a lot like attorneys, restaurants, artists: the best ones get more per hour/job and have longer waiting lists... the average or low level ones make less, charge less.
 
Agree... if I were going to remain in the game significantly longer, I would absolutely trend towards cash pay office (probably offer little/no surgery). It'd be powerful to be able to set your own prices... just like attorneys, mechanics, photographers, skilled trades, tech ppl, musicians, etc etc etc can (basically anyone besides docs).

Between the amount of things we have to do yet don't get paid for (work notes/forms, prior auth, Cme, etc etc) and then the work that gets "paid" yet denied or reduced or audited, it's pretty dicey.

Malpractice and EMR costs also seems to rise nearly as fast as tuition does. Staffing and basic utilities/rent and supplies sure don't go down. Reimbursements have not kept pace whatsoever with overhead (this is not unique to podiatry... but it's especially damaging as our ROI was lower all along).

This is the case for most old professions: a lot of red tape, licensing, liability. The difference for medicine is that we can't set our own prices (MCR does).
If we could, you'd see it being a lot like attorneys, restaurants, artists: the best ones get more per hour/job and have longer waiting lists... the average or low level ones make less, charge less.
I’m not doing any surgery really.. solo PP. not worth it. I carry the surgical malpractice still just for the toe amps or whatever I “have”to do. Some stuff you just can’t avoid like OM.

But bunions? Hammertoes? Fk no. These elective cases are only valuable if you get paid on rvu or can knock out three-five cases in a block time. I’m not built like that anymore. I don’t love podiatry that much, I’m here to make a living and try to be stress free and see my kids.

I get enough enjoyment out of ingrown nails that some people have to do recon’s for to get the same satisfaction. In the patients eyes they think I’m amazing for doing an ingrown.

But I didn’t join this profession because “I have to do surgery”. I wanted to just treat patients and I can do that in clinic. But this 25 modifier thing would be crushing.

I’m not sure how much volume direct care podiatrists see. It makes sense if you’re a pcp and can offer concierge services. But we’re specialists we usually see the patient once or twice and get them better and they move on….. why would they go to a cash pay doc vs someone who takes their insurance?

These reimbursements are very troubling for podiatry. Hospital RVU and limb salvage will likely be the best path forward for most……
 
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This is absolute bull****.

This is like half of our new patient visits. Office visit + nail avulsion. Office visit + plantar wart debridement. Office visit + wound debridement. Private insurance will follow this standard.

Why the **** do I take insurance at this point? These direct care podiatrists are probably onto something and then they never have to pay billers!

Because if you stop taking insurance then folks will just go to the other glut of available podiatrists on every corner.
 
Because if you stop taking insurance then folks will just go to the other glut of available podiatrists on every corner.
This is true in most areas. It will be a bit like chiropractors (we are already not too far off: wacky marketing, same day appts, lots of OTC, infighting).

...But it's a professional service. This will come to a head eventually as MCR rates stay stagnant and overhead costs rise. (just like Canada)

Think about attorneys: do most people use public defenders when charged with a crime or needing serious advice? I don't.
Do most people use low cost students to build their roof or fix their car or advise on investments? I don't.
So, will all people choose the Medicaid doctor because they are cheap or "free"? We'll see eventually. 🙂
 
I’m not doing any surgery really.. solo PP. not worth it. I carry the surgical malpractice still just for the toe amps or whatever I “have”to do. Some stuff you just can’t avoid like OM.

But bunions? Hammertoes? Fk no. These elective cases are only valuable if you get paid on rvu or can knock out three-five cases in a block time. I’m not built like that anymore. I don’t love podiatry that much, I’m here to make a living and try to be stress free and see my kids.

I get enough enjoyment out of ingrown nails that some people have to do recon’s for to get the same satisfaction. In the patients eyes they think I’m amazing for doing an ingrown.

But I didn’t join this profession because “I have to do surgery”. I wanted to just treat patients and I can do that in clinic. But this 25 modifier thing would be crushing.

I’m not sure how much volume direct care podiatrists see. It makes sense if you’re a pcp and can offer concierge services. But we’re specialists we usually see the patient once or twice and get them better and they move on….. why would they go to a cash pay doc vs someone who takes their insurance?

These reimbursements are very troubling for podiatry. Hospital RVU and limb salvage will likely be the best path forward for most……
💯


On a side note - insurances should stop trying to worry about what private practice is doing and focus on how much hospitals and surgery centers are robbing their pockets from via facility fees.
 
Capitation model is the way. FFS is just dying and not sustainable for our profession long term. Maybe it's CA that I am seeing more cap models as it's the HMO haven here, but I think it will eventually dominate the landscape.

At this time nearly 70% of my clinic volume is from 3 cap plans in the area. So far it's been working well. These plans see the value of outpatient podiatry to avoid costly inpatient visits. I get a nice profit share each year. E&M visits and routine care are not directly reimbursed (capitated) and surgeries are anywhere from 120-150% of Medicare rates. This actually made my billing easy.

I am becoming less and less motivated to see any medicare patients (both traditional medicare and MCA). Nothing drags you down more than an entitled boomer wanting everything covered. "Can you write a letter to Medicare about approving laser for my nails?" No. Go home and write a letter to your senator. A great majority of them don't have any symptomatic pathologies but are just there to talk. I think some of these folks just wake up in the morning and think about what they are going to complain about for the day.

PPOs and VA/Tricare are now reimbursing at nearly Medicaid levels. I laughed at my $60 collection for a Cigna PPO. F*ck that.

If our service is not valued by insurances then so be it. Drop the bad payors. Eventually your practice will align with the type of patients you want to see. I didn't believe it at first. I was so tempted to take free call because I was afraid of losing volume. I had to say yes to lots of BS referrals just because. But after a while I realized it's not worth it.
 
Capitation model is the way. FFS is just dying and not sustainable for our profession long term. Maybe it's CA that I am seeing more cap models as it's the HMO haven here, but I think it will eventually dominate the landscape.

At this time nearly 70% of my clinic volume is from 3 cap plans in the area. So far it's been working well. These plans see the value of outpatient podiatry to avoid costly inpatient visits. I get a nice profit share each year. E&M visits and routine care are not directly reimbursed (capitated) and surgeries are anywhere from 120-150% of Medicare rates. This actually made my billing easy.

I am becoming less and less motivated to see any medicare patients (both traditional medicare and MCA). Nothing drags you down more than an entitled boomer wanting everything covered. "Can you write a letter to Medicare about approving laser for my nails?" No. Go home and write a letter to your senator. A great majority of them don't have any symptomatic pathologies but are just there to talk. I think some of these folks just wake up in the morning and think about what they are going to complain about for the day.

PPOs and VA/Tricare are now reimbursing at nearly Medicaid levels. I laughed at my $60 collection for a Cigna PPO. F*ck that.

If our service is not valued by insurances then so be it. Drop the bad payors. Eventually your practice will align with the type of patients you want to see. I didn't believe it at first. I was so tempted to take free call because I was afraid of losing volume. I had to say yes to lots of BS referrals just because. But after a while I realized it's not worth it.
Its always interesting to me hearing about different payment models that sound so foreign/strange. To the best of my knowledge I've never been approached by/spoken to a capitation model insurance.

I'm a believer in dropping bad insurances but I'm also very much a believer that practices have to control their expenses. My former partner and I didn't see eye to eye on this and now he's paying those expenses by himself and I'm doing my own Xero book keeping.
 
Capitation model is the way. FFS is just dying and not sustainable for our profession long term. Maybe it's CA that I am seeing more cap models as it's the HMO haven here, but I think it will eventually dominate the landscape.

At this time nearly 70% of my clinic volume is from 3 cap plans in the area. So far it's been working well. These plans see the value of outpatient podiatry to avoid costly inpatient visits. I get a nice profit share each year. E&M visits and routine care are not directly reimbursed (capitated) and surgeries are anywhere from 120-150% of Medicare rates. This actually made my billing easy.

I am becoming less and less motivated to see any medicare patients (both traditional medicare and MCA). Nothing drags you down more than an entitled boomer wanting everything covered. "Can you write a letter to Medicare about approving laser for my nails?" No. Go home and write a letter to your senator. A great majority of them don't have any symptomatic pathologies but are just there to talk. I think some of these folks just wake up in the morning and think about what they are going to complain about for the day.

PPOs and VA/Tricare are now reimbursing at nearly Medicaid levels. I laughed at my $60 collection for a Cigna PPO. F*ck that.

If our service is not valued by insurances then so be it. Drop the bad payors. Eventually your practice will align with the type of patients you want to see. I didn't believe it at first. I was so tempted to take free call because I was afraid of losing volume. I had to say yes to lots of BS referrals just because. But after a while I realized it's not worth it.

Its always interesting to me hearing about different payment models that sound so foreign/strange. To the best of my knowledge I've never been approached by/spoken to a capitation model insurance.

I'm a believer in dropping bad insurances but I'm also very much a believer that practices have to control their expenses. My former partner and I didn't see eye to eye on this and now he's paying those expenses by himself and I'm doing my own Xero book keeping.
Havn't heard of capitation plans for podiatry.
The medicine guys are doing one right now and its a huge pain. The bonuses get in the way of patient care by limiting patient visits.
For specialists its probably not a big deal.

We treat one area, they may come back they may not.

Harder to do that on someone with 5 comorbidities- and probably harder on your pocket as the care that's needed will probably out earn any incentive they give you for capping the number of visits.
 
We used to have a cap plan before the hospital system nuked it a few years ago. I wasn’t a fan. Endless need for PCP referrals. Visits weren’t limited, but their allowed formulary was. Imaging and procedures were somewhere below Medicaid rates if I remember correctly. We did get bonuses to some degree, but they didn’t make up for it. We kept the plan only because it was such a large market share - better than having open appointment slots.

Sounds like they’re better in CA, so legitimately congrats.
 
Capitation model is the way. FFS is just dying and not sustainable for our profession long term. Maybe it's CA that I am seeing more cap models as it's the HMO haven here, but I think it will eventually dominate the landscape.

At this time nearly 70% of my clinic volume is from 3 cap plans in the area. So far it's been working well. These plans see the value of outpatient podiatry to avoid costly inpatient visits. I get a nice profit share each year. E&M visits and routine care are not directly reimbursed (capitated) and surgeries are anywhere from 120-150% of Medicare rates. This actually made my billing easy.

I am becoming less and less motivated to see any medicare patients (both traditional medicare and MCA). Nothing drags you down more than an entitled boomer wanting everything covered. "Can you write a letter to Medicare about approving laser for my nails?" No. Go home and write a letter to your senator. A great majority of them don't have any symptomatic pathologies but are just there to talk. I think some of these folks just wake up in the morning and think about what they are going to complain about for the day.

PPOs and VA/Tricare are now reimbursing at nearly Medicaid levels. I laughed at my $60 collection for a Cigna PPO. F*ck that.

If our service is not valued by insurances then so be it. Drop the bad payors. Eventually your practice will align with the type of patients you want to see. I didn't believe it at first. I was so tempted to take free call because I was afraid of losing volume. I had to say yes to lots of BS referrals just because. But after a while I realized it's not worth it.
I would be careful for what you wish for. Capitation for Podiatry can have negative effects on earnings. In Philadelphia area, capitation model for Podiatry by one of the most popular HMO plans has been in play for many years. For this BC/BS insurance carrier, one must accept its HMO plan, in order to get access to its PPO plan. For this HMO plan in the greater Philadelphia area, all forefoot procedures (distal to Lisfranc joint) are part of the capitation (thanks to the greedy older DPMs in the past). When a DPM performs a bunionectomy on a patient with this HMO plan, the DPM will be only receive what he/she gets from capitation fee for that patient for the procedure, which is ridiculous. This is why older DPMs would simply hire associates and have them perform all of the forefoot surgeries on patients with HMO plans. Of course, one can get creative with billing with capitated HMO plans. For these capitated patients, one would bill an E&M code and not bill for nail avulsion procedure (due to procedure being capitated) so that one can at least collect a copay for the nail avulsion procedure.
 
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I would be careful for what you wish for. Capitation for Podiatry can have negative effects on earnings. In Philadelphia area, capitation model for Podiatry by one of the most popular HMO plans has been in play for many years. For this BC/BS insurance carrier, one must accept its HMO plan, in order to get access to its PPO plan. For this HMO plan in the greater Philadelphia area, all forefoot procedures (distal to Lisfranc joint) are part of the capitation (thanks to the greedy older DPMs in the past). When a DPM performs a bunionectomy on a patient with this HMO plan, the DPM will be only receive what he/she gets for capitation fee for that patient for the procedure, which is ridiculous. This is why older DPMs would simply hire associates and have them perform all of the forefoot surgeries on patients with HMO plans. Of course, one can get creative with billing with capitated HMO plans. For these capitated patients, one would bill an E&M code and not bill for nail avulsion procedure (due to procedure being capitated) so that one can at least collect a copay for the nail avulsion procedure.
True. Not all cap plans are the same. This model only works well if one is seeing a large volume of diabetic patients. For the plans they just want to save money on hospital admissions. If you have an outpatient model that can get these high risk patients seen sooner then it can be a win-win for both parties.

But there is no way I am going to accept a plan that cap surgeries. Surgeries should be reimbursed separately. Reimbursement sucks even for FFS plans.
 
We used to have a cap plan before the hospital system nuked it a few years ago. I wasn’t a fan. Endless need for PCP referrals. Visits weren’t limited, but their allowed formulary was. Imaging and procedures were somewhere below Medicaid rates if I remember correctly. We did get bonuses to some degree, but they didn’t make up for it. We kept the plan only because it was such a large market share - better than having open appointment slots.

Sounds like they’re better in CA, so legitimately congrats.
Sir, we are lowly powe-die-a-trysts.

We think VA jobs are good, $48 per wRVU hospital jobs are great, and that making Medicare fee sched in PP is just dandy. 🙂
 
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Sir, we are lowly powe-die-a trysts.

We think VA jobs are good, $48 per wRVU hospital jobs are great, and that making Medicare fee sched in PP is just dandy. 🙂
Sir, what if I told you retina and oculoplastics doctors, with their 6 years of postgraduate training, make $36-$40 per wRVU in academics. If you can trust Marit, a couple of those folks almost certainly doxxed themselves based on the locations, which are 2 of the biggest name spots in the country. We’ve got some suckers in all fields.

The VA is actually an ok semi-retirement gig, jump in when you’re 55 and get the pension and healthcare for life. The only way it makes sense if you’re young is doing academics where you have residents doing all the work, take all your days off, and line up the benefits. My residency VA had a good number of lifers. So I’ll agree with you here. (Surgical pods are on the same pay table as eye docs btw).
 
Getting a Medicare audit. Major PITA, supposedly more likely with higher percentages. I’m only at 25-33%, but they wanted charts on like 30 patients per doc in our group. Took a couple months, decent bit of staff time. Everything was on the up and up, no claw backs, but zero fun was had other than giving them the finger and knowing they probably won’t come back again any time soon.
30 percent or higher is considered excessive E And M with procedure by Medicare formulas…
 
Where other fields in medicine blow us out of the water is they can easily see a high volume of patients if they want because they are in high demand. Ive heard some pods claim they see 50+ a day but I don’t think that’s very common. And I’m sure those 50 patient days are half filled with keratin.
 
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Where other fields in medicine blow us out of the water is they can easily see a high volume of patients if they want because they are in high demand. Ive heard some pods claim they see 50+ a day but I don’t think that’s very common. And I’m sure those 50 patient days are half filled with keratin.
A lot if them probably are. And random ancillaries and reappointments for BS
 
Where other fields in medicine blow us out of the water is they can easily see a high volume of patients if they want because they are in high demand. Ive heard some pods claim they see 50+ a day but I don’t think that’s very common. And I’m sure those 50 patient days are half filled with keratin.
Well, we also pay our associate PP docs closer to PA/NP wage (whereas MD associates command better money... and will usually demand partnership also).

But yeah, to make a lot in podiaty, you basically need to keep a % off other podiatrists, see a ton of patients yourself, or both.

So, if you want to make a lot in podiatry, be a large/supergroup owner. 🙂
 

Accounting for Overlap Between Stand-Alone E/M Visits and Global Periods

For CY 2027, we are proposing to reduce payment when a separately identifiable office/outpatient evaluation and management (E/M) visit is furnished by the same physician (or a physician in the same practice) on the same day as a 0-, 10-, or 90-day global procedure. The most expensive service (either surgical or E/M visit) would be paid at 100% and all other surgical procedure(s) or E/M visit(s) furnished on the same day would be paid at 50%.

This proposed policy is like a proposal in the CY 2019 PFS proposed rule, made in the context of a broader proposal that would have modified the payment structure of E/M visits. While we did not finalize the proposal at that time, we noted that we continued to believe that there are efficiencies when the same physician (or a physician in the same group practice) provides an E/M service for the same patient in conjunction with a procedure with a global period and that we are likely duplicating payment under the current payment methodology. The current proposal would address that overvaluation.

*This was apparently previously proposed in 2019 but was not implemented.
Podiatrist do what always done… over utilize and over bill
 

Accounting for Overlap Between Stand-Alone E/M Visits and Global Periods

For CY 2027, we are proposing to reduce payment when a separately identifiable office/outpatient evaluation and management (E/M) visit is furnished by the same physician (or a physician in the same practice) on the same day as a 0-, 10-, or 90-day global procedure. The most expensive service (either surgical or E/M visit) would be paid at 100% and all other surgical procedure(s) or E/M visit(s) furnished on the same day would be paid at 50%.

This proposed policy is like a proposal in the CY 2019 PFS proposed rule, made in the context of a broader proposal that would have modified the payment structure of E/M visits. While we did not finalize the proposal at that time, we noted that we continued to believe that there are efficiencies when the same physician (or a physician in the same group practice) provides an E/M service for the same patient in conjunction with a procedure with a global period and that we are likely duplicating payment under the current payment methodology. The current proposal would address that overvaluation.

*This was apparently previously proposed in 2019 but was not implemented.
One answer, a local podiatrist to me. Residency director. Billed and collected on11 patients-787K! Wound care product. Thankfully Medicare flush with cash…
 

Accounting for Overlap Between Stand-Alone E/M Visits and Global Periods

For CY 2027, we are proposing to reduce payment when a separately identifiable office/outpatient evaluation and management (E/M) visit is furnished by the same physician (or a physician in the same practice) on the same day as a 0-, 10-, or 90-day global procedure. The most expensive service (either surgical or E/M visit) would be paid at 100% and all other surgical procedure(s) or E/M visit(s) furnished on the same day would be paid at 50%.

This proposed policy is like a proposal in the CY 2019 PFS proposed rule, made in the context of a broader proposal that would have modified the payment structure of E/M visits. While we did not finalize the proposal at that time, we noted that we continued to believe that there are efficiencies when the same physician (or a physician in the same group practice) provides an E/M service for the same patient in conjunction with a procedure with a global period and that we are likely duplicating payment under the current payment methodology. The current proposal would address that overvaluation.

*This was apparently previously proposed in 2019 but was not implemented.
Old saying if don’t regulate your self’s someone else will. Over utilization- government crackdown
 
Getting a Medicare audit. Major PITA, supposedly more likely with higher percentages. I’m only at 25-33%, but they wanted charts on like 30 patients per doc in our group. Took a couple months, decent bit of staff time. Everything was on the up and up, no claw backs, but zero fun was had other than giving them the finger and knowing they probably won’t come back again any time soon.
Glad came out ok but one risk factors for audit is having one done
 
This would absolutely be brutal for podiatry. Any updates on this? What’s the best way to lobby against this?
 
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Glad came out ok but one risk factors for audit is having one done
In theory, but the only way to have that make sense is if there were clawbacks. Why re-audit groups 100% in compliance instead of prior offenders or trying fresh meat? Waste of limited resources, but it’s not like CMS is logical.

If you missed the above update, I’m only at 16% -25s so it’s likely just sheer volume that got us a look.
 
This would absolutely be brutal for podiatry. Any updates on this? What’s the best way to lobby against this?
It’s currently in the comment period. There’s a website with the text of the changes and everyone can submit their comments on it. Might be more effective than contacting a congressman who likely doesn’t care unless you’re a donor.

Here