CMS Is Still Questioning Those Global Surgical Visits

By Jennifer McNamara | Healthcare Inspired

CMS has been examining global surgical payments for years, and the 2027 Physician Fee Schedule continues that work.

The agency finalized a pause in the postoperative visit data collection required under the Medicare Access and CHIP Reauthorization Act (MACRA). At the same time, CMS said its existing data suggest that some postoperative visits assumed in global surgical payment are not occurring.

I expect that statement to generate concern among surgeons. I also think we need to separate the data collection decision from the larger reimbursement discussion.

CMS paused a reporting requirement. It did not eliminate the global surgical package or conclude that every missed postoperative appointment represents an improperly billed service.

Global payments are based on assumptions about care.

A 10- or 90-day global surgical payment generally reflects a package of services, including certain related postoperative care. Medicare's valuation assumes a particular amount of physician work and practice expense over that period.

CMS wants to know whether the visits assumed in those valuations resemble what happens in actual practices.

That is a reasonable question, but surgical recovery is not identical for every patient. The number and nature of postoperative encounters depend on the procedure, the patient's clinical course, complications, and the way the surgeon organizes follow-up care.

A patient who recovers without an in-person visit is different from a patient whose follow-up care was never arranged. The data need to be interpreted carefully before drawing conclusions about physician work or payment accuracy.

I would review the postoperative workflow, not just the visit count.

When I'm reviewing surgical services, I want to understand the care that was actually furnished.

Was a follow-up visit scheduled? Did the patient attend? Was the postoperative assessment documented? Were there phone calls, portal communications, or other clinical activities? Who provided the care, and how is that reflected in the record?

Not every activity is a separately billable visit, and not every postoperative encounter is separately payable during a global period. But the clinical record should accurately describe the care delivered.

I'd also look for inconsistent processes between surgeons. One physician may routinely document postoperative assessment in the EHR, while another uses a different workflow that is difficult to track in a claims-based analysis.

A practice needs to know whether it has a documentation problem, a scheduling problem, or simply a variation in clinically appropriate follow-up.

The pause should not be confused with a permanent policy decision.

CMS has not finalized a broad reduction to all 10- and 90-day global surgical payments under this provision. It is continuing to evaluate the data and possible approaches to global service valuation.

The agency also received feedback expressing concern about administrative burden from expanded postoperative visit reporting.

I understand those concerns. Additional reporting requirements can consume time without necessarily producing a complete picture of clinical care.

But I would not assume the payment questions are going away. CMS has made clear that it intends to continue reviewing how global payments are valued.

What I would want a surgical practice to do

I would pull a sample of recent procedures with 10- and 90-day global periods and review the postoperative documentation against the expected care pathway.

Look for missed appointments, undocumented work, inconsistent use of postoperative visit workflows, and confusion about which services are included in the global package.

I would also make sure the coding team understands the difference between routine related postoperative care, unrelated conditions, complications, and services that may qualify for separate reporting under applicable Medicare rules.

No one should change a surgical patient's follow-up plan to satisfy a presumed visit count. The care should be based on clinical need, and the documentation should describe what occurred.

If CMS ultimately changes global surgical valuations, practices will need a reliable picture of their current postoperative work to evaluate the impact.

I would rather begin with that review now than wait for a future reimbursement proposal and try to reconstruct the data later.

Next in the series: Remote monitoring vendors, initiating visits, and the new Medicare requirements.

SOURCE CMS: CY 2027 Medicare Physician Fee Schedule Final Rule (November 4, 2026)