Evaluation and Management FAQs

Global Period Services

  1. Is it permissible for a provider (physician or NPP) who has served as an assistant surgeon, or another provider in the surgeon’s group, to bill for preoperative or postoperative care relative to the surgery?

    Answer:
    The global surgery fee is paid to the primary surgeon and includes compensation for all standard elements of the surgery (pre, intra and postoperative care). This care is not separately billable or payable to the assistant surgeon or to any member of the primary surgeon’s group, unless the surgeon has transferred a specific segment of that care to another provider. If the surgeon has transferred that care to another provider, then the surgeon must use the modifier -54 (surgical care only) and the modifier -56 (preoperative care only).
     
  2. How do global period rules apply to critical care services?

    Answer: Global surgery rules apply to the primary surgeon who performed and billed the surgical service that established the global period. When the primary surgeon performs a critical care service within the global period for a problem unrelated to the surgery, the surgeon bills the critical care service with modifiers 24 and FT. (Modifier FT is effective 1/1/2022, and required 3/1/2022).
     
  3. If a surgery/procedure is cancelled pre- or post anesthesia induction, can the surgeon bill an E/M based on the preoperative history, examination and plan that is documented, detailing why the surgery was cancelled?

    Answer:
    When a surgical procedure is cancelled in this situation, the surgeon’s preoperative E/M service is no longer bundled into the surgical package and may be separately billed. If the surgery were to be performed later that same day, the E/M would again be bundled into the package.
     
  4. What constitutes “start of procedure” per CMS?

    Answer:
    CMS considers surgical incision (or start of procedure if no incision required) as the start time for the procedure.
     
  5. What scenario/situation is appropriate for use of modifiers 24 and 25 on the same claim for an E/M service, e.g., 99212 24/25?

    Answer:
    Modifier 24 describes an E/M service during a global period, unrelated to the procedure that established the global period, while modifier 25 describes a separately identifiable E/M service when a procedure is performed during the same encounter. The need for both of these modifiers on the same claim during a global period would be unusual; the following scenario is an example of a scenario in which both modifiers could be used:
    • A patient is seen by the operating surgeon for an office f/u mid-level visit, two weeks after a hemi-colectomy. During the visit, the patient presents with an infected abscess on the right shoulder. The provider addresses this unrelated problem and recommends a course of antibiotics. This service could appropriately be billed as 99213 24, since it is unrelated to the hemi-colectomy.
    • If the provider scheduled the patient for a f/u visit for possible I&D of the abscess, and the patient presented with two additional abscesses that required further evaluation, billing for the second visit could include 99213 24/25, along with, along with CPT 23030 for the I&D.

Reviewed 4/15/2024