Groups call on CMS to scrap the 'burdensome' proposal, which 40% of survey respondents anticipate will cost between $25,000 to $100,000 per surgeon.
CMS's global surgery data collection proposal is onerous, unfunded, and would "wreak havoc" on surgeons' practices, according to comments to CMS by the American Association of Neurological Surgeons (AANS) and Congress of Neurological Surgeons (CNS).
The 2017 Medicare Physician Fee Schedule includes what the AANS and CNS called a "sweeping mandate" that would require surgeons to use a set of eight "new and untested G-codes" to document the type, level, and number of every pre- and postoperative visit furnished during the global period of every surgical procedure.
According to the proposal, surgeons would have to report on each 10-minute increment of services provided.
"The proposed time-based G-codes are not aligned with clinical workflow," the comments said. "The burden associated with physicians attempting to track their time in 10-minute increments is onerous and will result in underreporting of data."
Currently, Medicare pays neurosurgeons a single fee which covers the costs of the surgery plus all follow-up care within a 10- or 90-day timeframe.
In addition, the comments say that the proposal runs afoul of Medicare Access and CHIP Reauthorization Act (MACRA) directives, which directs CMS to gather data from a 'representative sample of physicians.'
"The AANS and CNS are extremely disappointed that CMS has proposed a policy to collect data on all 10- and 90-day global services from all physicians who perform these services," the groups stated in their comments.
The groups cited their survey of 7,071 surgeons and anesthesiologists, conducted in August, that demonstrated how burdensome and costly the new requirement would be.
"Nearly 40% of respondents anticipate it will cost them between $25,000 to $100,000, and another 30% estimate they will spend more than $100,000 on compliance," the survey stated.
If the CMS requirements were enacted, survey respondents said they would have to:
- Modify EHR and billing systems (85.9%)
- Incur additional physician (88.8%) and staff (75.7%) time spent on tracking and processing global surgery information into EHR and billing systems
- Develop new methods for tracking and collecting global surgery visit work (82.8%)
- Use additional technology, such as handheld devices or stopwatches, to document time spent providing global surgery services (46.4%)
"The claims-based data collection mandate is so burdensome that most physicians will not be able to comply by January 1, 2017, which will result in CMS being unable to collect accurate and usable data, particularly in light of the unfinished final rule at the time of this writing," they wrote.