Dec 23, 2025
Written By Elizabeth Cifers
When Medicare determines the payment for a surgical procedure, that payment covers more than just the operation itself. The Physician Fee Schedule includes the global post-op days for 10- and 90-day procedures, which account for the post-op care a surgeon is expected to provide. The idea is to have the payment for the entire episode of care, not just the surgery, but the global period.
In ophthalmology, this means that routine follow-up visits after procedures such as vitrectomy or retinal detachment repair are already covered in the surgical payment. Separate claims for these routine visits are neither expected nor allowed unless the care is unrelated or goes beyond what is normally included.
Under the Medicare Access and CHIP Reauthorization Act (MACRA), CMS is required to collect and analyze data on the number and level of post-op visits actually provided. The agency’s Global Surgery Data Collection initiative uses CPT 99024 to gather that information.1
The 2017 rule restricted mandatory 99024 reporting to nine states (FL, KY, LA, NV, NJ, ND, OH, OR, and RI) and groups with ten or more providers. However, CMS’s 2025 monitoring activities indicate this limited sample might grow. The OIG’s 2025 audit criticized CMS for failing to verify compliance even among those required to report, which raises the chance of expanding oversight or enforcement.
CMS has already indicated that if the data continue to show lower-than-expected post-op visits, work RVUs for global surgery codes could decrease to reflect actual post-op visits. Essentially, future fee schedule updates might lower surgical reimbursement without any formal rule change, simply through revaluation based on empirical data.
Recent analyses indicate that, in many specialties, the actual number of post-op visits physicians provide is significantly lower than what CMS assumed when valuing the global surgical codes.
The OIG estimated that nearly $7.8 million in Medicare payments and $4.8 million in patient coinsurance could be higher than necessary if global surgery fees accurately reflected actual post-op utilization. Their recommendation to CMS is to verify that it receives global post-op data from physicians who are expected to report postoperative visits and to notify the physicians when data is not received.
The American Medical Association’s August 2025 Advocacy Update confirmed that AMA and OIG officials discussed the findings, noting that a re-evaluation of global surgery codes is likely if under-utilization continues.3
CMS continues to review whether global surgical payments reflect the care actually provided before, during, and after surgery. The 2025 and 2026 Physician Fee Schedule rules highlight ongoing assessment of global-package accuracy and how payments are divided when multiple providers are involved in a patient’s surgical episode.
Although retina surgeons rarely use transfer-of-care designations, CMS’s focus on post-op accountability stresses the importance of clear documentation of who performs follow-up visits and how the care is managed.
Even if your practice isn’t in a reporting state or a large group, the OIG’s findings suggest that global-period compliance is becoming a national audit focus. CMS may start reviewing claims for missing post-op data, inconsistent reporting, or inadequate documentation. Submitting post-op encounters (even when not required) strengthens audit readiness, shows continuity of care, and positions retina practices well if CMS expands data collection requirements in the future.
If CMS finds that retina surgeons routinely provide fewer follow-up visits than expected, RVUs and payments for 10- or 90-day global procedures could be reduced. Retina groups should document post-op encounters within the global period, even though they are no-charge services, to confirm compliance.
Run reports in your practice management system to review the average number of post-op visits per procedure or surgery for 10- and 90-day globals, and compare the results against CMS’s built-in number of post-op visits. Understanding your utilization now helps prevent audit issues later.
The discussion about global post-operative days is current and may soon become part of active policy and audit practices. OIG’s 2025 report and CMS’s ongoing data collection clearly aim to link payment with actual resource use. For retina and other surgical specialties, maintaining accurate documentation, correctly using modifiers, and being aware of emerging valuation changes are now essential areas of focus for compliance.
Audit readiness isn’t about being perfect, but about being prepared. Retina practices that proactively review post-operative documentation and track the global period will be better positioned if CMS and OIG oversight expands. To learn more or schedule a focused review of your documentation and compliance processes, contact ECC to start the conversation.
1CMS, Global Surgery Data Collection (2025), https://www.cms.gov/medicare/payment/fee-schedules/physician/global-surgery-data-collection
2U.S. Dept. of Health and Human Services, OIG Report A-05-20-00027 (2025).
3American Medical Association, Advocacy Update (Aug 15, 2025).
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