Global Surgical Payment

The Academy supports payment relativity and parity between office evaluation and management (E/M) visits and the postoperative visits bundled into 10- and 90-day global surgical packages. We urge CMS to apply the 2021 office E/M valuation to the postoperative visits included in global codes, consistent with recommendations from the AMA/Specialty Society RVS Update Committee (RUC) and the explicit statutory requirement that the Secretary of Health and Human Services may not vary relative value units (RVUs) for the same physician service based on specialty.

If CMS has concerns about the valuation of specific codes, those concerns should be addressed through the established RUC misvalued codes process — not through unilateral inaction. The Academy opposes policies that add administrative burden without resolving the underlying payment inequity, including the 2025 expansion of the transfer of care modifier -54 requirement. We also oppose proposals to convert 10- and 90-day global codes to 0-day codes, which would disrupt established surgical care, increase beneficiary cost-sharing for follow-up visits, and disproportionately harm ophthalmology and our patients.

The Academy collaborates with the Surgical Coalition to advocate for global surgical payment parity. Our organizations submit comprehensive comment letters to CMS during each annual Medicare Physician Fee Schedule rulemaking cycle, consistently urging CMS to apply the 2021 E/M update to postoperative visits included in global surgical packages. 
These annual comment letters also address global surgical code valuation as part of our broader Medicare reimbursement advocacy.

The Academy engages Congress directly and regularly on this issue through meetings with congressional offices, testimony, and targeted correspondence to key committees. In June 2024, for example, the Academy sent a letter to the Senate Finance Committee urging Congress to press CMS toward equitable postoperative E/M payment. Academy physician leaders and staff have also met directly with MedPAC, an independent congressional agency that advises Congress on issues affecting the Medicare program, to refute the mischaracterization of cataract surgery as overvalued in MedPAC's June 2024 Report to Congress, and continue to monitor MedPAC's recommendations, which contemplate either converting 10- and 90-day codes to 0-day codes or rebasing global RVUs.

The Academy also provides members with practical coding guidance on transfer of care modifiers and the HCPCS add-on code G0559. 

Comply with 2025 requirements

The expanded transfer of care modifier requirements and G0559 add-on code documentation and billing guidelines took effect January 1, 2025. Ensure your practice is in compliance.

Report postoperative visits if required

If your practice is part of CMS's postoperative visit data collection policy, submit CPT code 99024, Postoperative visit, on all applicable Part B claims. See the Academy's Postoperative Visit Reporting resource for details on which states, practices, and codes are affected.

Stay informed

Watch for updates on global surgical payment policy in the weekly Washington Report Express newsletter sent to AAO members, and the monthly Practice Management Express newsletter sent to AAOE members.

The global surgical package bundles payment for a procedure with related preoperative care (after the decision to operate), intraoperative services, and postoperative care. Procedures are classified as having a 0-day, 10-day, or 90-day global period depending on the procedure type and typical postoperative care involved.

CMS has repeatedly stated its belief that global surgical codes are overvalued because the operating surgeon (or another provider in the surgeon’s group practice) is not always performing all the postoperative visits included in the global surgical package. Thanks to the advocacy efforts of the Academy and Surgical Coalition, the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) barred CMS from eliminating 10- and 90-day global surgical payments, which the agency deemed misvalued. Instead, the law authorized CMS to collect data on such services from a representative sample of physicians to review the valuation of surgical codes. In response, CMS began collecting postoperative visit data from group practices in nine states: Florida, Kentucky, Louisiana, Nevada, New Jersey, North Dakota, Ohio, Oregon, and Rhode Island. Since July 1, 2017, affected providers must report CPT code 99024, Postoperative visit, on Part B claims for surgical procedures with 10-day or 90-day global periods.

In 2021, CMS finalized substantial increases to the office and outpatient E/M codes (99202–99215) — but declined to apply the same increase to the equivalent postoperative E/M visits valued within global surgical packages. This created a structural payment inequity: CMS pays more for the same E/M service when it is billed outside a global surgical package than inside one. CMS has refused to correct this inequity in subsequent rulemaking cycles despite consistent RUC recommendations to do so. Instead of resolving the inequity, CMS has repeatedly deferred to policies around data collection. The Academy continues to push Congress and CMS to restore parity.