Dear Secretary Burwell and Acting Administrator Slavitt:
We are writing to express our opposition to the provision in the Centers for Medicare and Medicaid
Services’ (CMS) Physician Fee Schedule (PFS) proposed rule for calendar year (CY) 2017 to collect all data
for all 10- and 90-day global services from all practitioners who perform these services, rather than from
a “representative sample” of practitioners, which was required by The Medicare Access and CHIP
Reauthorization Act of 2015 (MACRA),
Congress was united in opposition to the policy in the CY 2015 PFS final rule that would have
transitioned all 10- and 90-day global codes to 0-day global codes beginning in 2017, because of
concerns that the change would compromise patient care and significantly increase administrative
burdens. Instead, Congress required CMS to collect data, starting January 1, 2017, on the number and
level of visits furnished during the global period. Specifically, Section 523 of MACRA explicitly calls for
CMS to gather information needed to value surgical services from a “representative sample” of
physicians. Beginning in 2019, CMS must use these data to facilitate accurate valuation of surgical
services.
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