Gift Tee
Director, Practitioner Services, Center for Medicare
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244
Re: CMS Meeting with Surgical Specialty Representatives on Global Codes Update
Dear Mr. Tee,
Thank you for the opportunity to meet on September 7, 2021, to discuss our concerns with the
current Centers for Medicare & Medicaid Services (CMS) policy regarding the evaluation and
management (E/M) post-operative office visits within global surgery codes. We remain strongly
opposed to CMS’ position not to incorporate the American Medical Association
(AMA)/Specialty Society Relative Value Update Scale Committee (RUC)-recommended work
and time incremental increases to the work relative value units (RVUs) for 10- and 90-day global
codes commensurate with the increases to discrete E/M codes that were implemented on January
1, 2021. As we have mentioned in prior letters to CMS, this creates specialty work differentials,
which is contrary to the Medicare statute. The current policy implies that physician work for an
office visit is less when performed in a surgical global period. That is simply not correct.
Read full letter here
