Postoperative Care Documentation, Coding and Evaluation and Management
Introduction
It can sometimes be confusing to decide what services can be billed for in the postoperative period. This often results in omission of valid charges and lost revenue. Therefore, it is imperative that the service provider be familiar with what is allowable. Services not covered in the global period of an operation must be recognized and captured to maximize reimbursement.
Many surgeons believe that they are not able to bill for such care in the form of Critical Care Evaluation and Management (E/M) services using CPT codes 99291 and 99292 when they have operated on the patient who requires critical care services. However, it is commonly the case that the operating surgeon can bill for surgical critical care as well as any other E/M service (such as a daily inpatient visit CPT code: 99231, 99232, or 99233) if certain conditions are met. Following is further guidance on this issue with a historical perspective on how the rules were developed.
Defining the postoperative period for billing purposes
There are three types of global surgical packages with a different number of postoperative days included in each.
0-Day postoperative period (minor procedures such as endoscopies, arterial and central line insertion, etc.)
10-Day postoperative period (other minor procedures, excision of skin lesions, I&D of abscess, intermediate and complex repairs, etc.). There is no preoperative period and includes services provided on the surgical day and 10 days following the day of surgery.
90-Day postoperative period (major procedures, for example, splenectomy, bowel resection, gastrostomy, etc.). A 1-day preoperative period is included, along with the day of surgery and then 90 days following the surgery.
A complete listing of postoperative periods for surgical procedures can be found in the Medicare Physician Fee Schedule (https://www.cms.gov/apps/physician-fee-schedule/overview.aspx).
Global Surgical Package (SGP): included services
The following services are included in the SGP payment and cannot be billed for separately:
Follow-up visits during the postoperative period of the surgery that are related to routine recovery from the surgery.
Postoperative pain.
Supplies, except for those identified by the surgeon (eg, surgical implants).
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. VAC changes would be included if the patient is in the 10-day or 90-day global period.
Follow-up in office care, including treatment of complications not requiring a return to the operating room, is included in postoperative surgical package. Also, typical in-hospital follow-up care is included in the postoperative surgical package. If critical care services are being rendered, it is logical to appropriately and legitimately bill for them, as payments will be higher.
Global Surgical Package: excluded services
These are services that are not included and may be billed for separately. Note that modifiers must be applied in some instances in order to obtain reimbursement. This extensive list of excluded services along with more information on the SGP can be found here:
Coders are not clinicians and rely on physician documentation as to why a patient is seen during postoperative period. Documentation should be clear to the coder that the patient is being seen for another condition(s) not related to the surgery. In fact, it is extremely useful to make the focus of a daily progress note be that of the other unrelated conditions and only mention the operation in passing; that will help emphasize the point that the care being provided during this particular encounter is for a condition that is unrelated to the operation.
More information on global periods is available in the Medicare Global Surgery Booklet found online (www.cms.gov).
A restricted understanding of what is meant by “unrelated to the surgery” is essential. The focus is specifically related to the surgical procedure performed on a specific part of the body.
Adding modifier 59 on the charge for any additional procedure (eg, central line) will permit that additional procedure to be reimbursed.
Commonly, those conditions that make a patient critically ill are usually not a routine consequence of a surgical procedure. For example, a patient may develop severe respiratory failure needing mechanical ventilation postoperatively from a bowel resection; respiratory failure is not a “usual, customary, or reasonable” consequence of that procedure. Therefore, it follows that it is not part of the surgical global package postoperatively and billing for care to treat them is allowable using the appropriate modifiers where applicable.
Conclusion
It should be a rare occasion that a surgeon cannot bill for critical care services and procedures on a patient on whom they have operated on. Such billing does, however, require the appropriate documentation and coding to enable payment for those services during the surgical global package period. Knowledge of, and appropriate application of, modifiers is important in order to clearly represent the relationship between the initial operation, subsequent operations and critical care services and procedures performed perioperatively.
The following resources provide additional information on this topic.
https://www.cms.gov/ (accessed May 18, 2020)
https://www.cms.gov/apps/physician-fee-schedule/overview.aspx (accessed May 18, 2020)
Mabry CD. In their own words. The Five-Year Review, E&M services, and ACS leadership. Bull Am Coll Surg 1998;83:41–5.
Reed RL 2nd, Luchette FA, Esposito TJ, et al. Medicare’s “Global” terrorism: where is the pay for performance? J Trauma 2008;64:374–83; discussion 383–4.
Medicare Claims Processing Manual, Chapter 12 – Physicians/Nonphysician Practitioners, Section 40.1: Definition of a Global Surgical Package. 90–94.
https://www.aapc.com/blog/46373-your-quick-guide-to-the-global-surgical-package/ (accessed June 1, 2020)
Medicare Claims Processing Manual, Chapter 12 – Physicians/Nonphysician Practitioners, Section 30.6.12 – Critical Care Visits and Neonatal Intensive Care (Codes 99291–99292), Subsection J: Critical Care Services and Other Procedures Provided on the Same Day by the Same Physician as Critical Care Codes 99291–99292. 74.
https://campus.ahima.org/audio/2007/RB020807.pdf (accessed June 9, 2020)