[co-author: Francis Han]
In August 2025, OIG released report A-05-20-00027, evaluating whether CMS is receiving the postoperative visit data that it requires from practitioners subject to Medicare’s global surgical package reporting rules. OIG’s findings highlight oversight gaps and carry important implications for compliance and payment policy.
Background
Congress, through the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), directed CMS to collect data on the number and level of postoperative visits furnished during global surgical periods. The purpose of this requirement was to ensure that the valuation of global surgical packages accurately reflects the services provided. In response, CMS required practitioners in nine states to begin reporting postoperative visits for select high-volume or high-cost procedures in July 2017. These data are intended to inform CMS’s evaluation of payment policies for global surgical services.
Key Findings
OIG found that CMS cannot confirm whether it is receiving all required postoperative visit data from practitioners. Under the reporting program, practitioners were expected to submit postoperative visit information for designated procedures, but CMS did not have controls to verify compliance.
OIG’s audit of a stratified random sample of claims identified multiple reporting failures:
- Some practitioners furnished postoperative visits but did not submit CPT code 99024 as required. OIG noted that this occurred, for example, when a physician performed surgery in a private practice but the postoperative care was furnished in a clinic not associated with that practice, and the billing staff did not have access to the relevant medical record.
- Other practitioners submitted CPT 99024 but reported an incorrect number of visits compared to what was documented in the medical record.
- OIG also found instances where the medical record did not align with the reporting. In some cases, visits were omitted from the record altogether, while in others, postoperative visits were misclassified, such as being reported separately as evaluation and management services rather than as global postoperative visits.
Because CMS does not have a process to notify practitioners when required postoperative data have not been reported, these gaps go undetected. OIG concluded that CMS may therefore be relying on incomplete or inaccurate data when evaluating whether global surgery payments reflect the services actually delivered. Based on its sample results, OIG estimated that Medicare paid about $7.8 million more (Medicare patients paid about $4.8 million more) than would have been paid if global surgery fees had reflected the actual number of postoperative visits.
Implications for Practitioners
The OIG report underscores that practitioners subject to postoperative visit reporting requirements must ensure complete and accurate submission of data. Although the audit focused on CMS’s oversight, the findings highlight several risks for the provider community:
- Compliance risk. Practitioners who fail to report postoperative visits as required may face heightened scrutiny from CMS or future OIG audits.
- Payment policy impact. Because CMS relies on these data to evaluate whether global surgery payment rates reflect actual practice, incomplete reporting could contribute to changes in the structure or valuation of global surgical packages in future rulemaking.
- Operational considerations. Practitioners should review their processes for capturing, documenting, and reporting postoperative visits—particularly the use of CPT 99024—to ensure alignment with CMS requirements.
By reinforcing reporting practices now, practitioners can reduce compliance risk and be better prepared for potential changes to Medicare payment policy.
