Comment Letter

Reps. Bera and Bucshon Urge CMS to Increase Global Surgery Codes

  • Reimbursement and Practice Management

The Honorable Chiquita Brooks-LaSure
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
7500 Security Boulevard
Baltimore, MD 21244

Dear Administrator Brooks-LaSure:

We write to express our concern with the current Center for Medicare & Medicaid Services (CMS) policy regarding the values of evaluation and management (E/M) office visits within global surgery codes. The CY 2023 proposed Medicare Physician Fee Schedule (PFS) once again fails to incorporate the adjusted values for the revised office/outpatient visit E/M codes into the 10- and 90-day global surgery codes, leaving surgeons systematically underpaid for these E/M services relative to other physicians performing the same services. This is the third rulemaking in which CMS seeks to perpetuate this disparity in pay for E/M services. We urge CMS to apply updated E/M values to the global codes in the upcoming CY 2023 Medicare PFS final rule to ensure that these physicians are compensated the same for providing equivalent services as defined by the Medicare statute.

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