September 23, 2016

AAFP Submits Blunt Comments on Physician Fees

The American Academy of Family Physicians’ (AAFP) August 19 comment letter on the Calendar Year (CY) 2017 Medicare Physician Fee Schedule (MPFS) proposed rule includes extensive remarks on the Centers for Medicare and Medicaid Services’ (CMS’) annual review of potentially misvalued codes, especially the effort to examine global surgical services.

The payment rate for many surgical services includes the procedure itself and certain services that are provided immediately before and after the procedure. Referred to by the Agency as the global package, CMS currently reimburses for 0-day, 10-day and 90-day global surgical services.

CMS finalized a proposal to eliminate the global package policy through the CY 2016 MPFS rulemaking cycle. Congress, however, included provisions in the Medicare Access and CHIP Reauthorization Act (MACRA) prohibiting the policy’s implementation and mandating CMS develop a data collection process to better assess global surgical services.

In response, the CY 2017 MPFS proposed rule requires physicians, despite not being paid separately for these services, to submit claims with new G codes for each visit provided during the pre- and post-operative period of a global code. The new codes would indicate the place of service, the service’s complexity, whether it was provided by a practitioner or clinical staff and the visit’s length of time recorded in 10-minute increments. The 10-minute increment recording process received considerable condemnation from numerous other national surgical societies as being overly burdensome.

AAFP, however, expressed strong support for CMS’ global surgical data collection process and used the opportunity to attack so-called “misvalued” procedures found throughout the fee schedule on page 13:

We note that CMS is likely to receive a significant amount of pushback to its proposal from some physician specialties. Ironically, it was those same specialties who advocated for the provision in the law that CMS is now trying to implement, because they were otherwise unhappy with CMS’s plans to convert all 10- and 90-day global surgical services to 0-day global periods. Had CMS been allowed to implement its planned change in global surgical services, none of this proposed effort would have been necessary. The fact remains that Medicare has been hemorrhaging funds as a result of misvalued procedural services for decades. We urge CMS to stand firm in its effort to excise, eviscerate, and amputate bloated relative values in the fee schedule (emphasis added). We will be happy to assist CMS in this particular operation to rationalize RVUS.

For questions on the global surgical policy or the AAFP’s position, please contact Chris Sherin ( in the ACR government relations office.