Re: Collecting Data on Resources Used in Furnishing Global Services
Dear Secretary Price and Ms. Verma:
On behalf of the 23 undersigned organizations of the surgical coalition, we write to express concern with
the implementation of the Centers for Medicare & Medicaid (CMS) policy requiring data collection on
global services as finalized in the calendar year (CY) 2017 Medicare Physician Fee Schedule (MPFS)
Final Rule. Our organizations put the welfare of our surgical patients above all else, and we urge CMS to
view policy changes through the lens of any potential impact on patients by focusing initially on the best
care delivery models and then developing appropriate payment models to facilitate these care delivery
models. We support policy changes that improve patient care and increase the accuracy of physician
reimbursement, but CMS’ data collection policy on global codes currently lacks sufficient information on
its implementation and has already posed a serious barrier to the collection of accurate data.
Before data collection begins, we ask that CMS share a detailed plan for data validation, provide answers
to outstanding questions, and assure providers that all claims submitted with the required data will be
captured. We do not think it is appropriate to begin the collection of data on July 1, 2017, before
CMS has addressed these issues and provided adequate time for provider education. If CMS
continues with its plan to collect data even though it has not provided sufficient information in advance
that allows for physician education and familiarity necessary to comply with the policy, the data will be
inherently flawed and of low statistical quality. We strongly urge the Agency to avoid using such data to
revalue global services starting in 2019.
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