Post-Op Global Period Changes From 90 To Zero Days For Common Digital Amputation Procedures

The new year has brought a significant change for the CPT^® 28820 and 28825 global periods.

To review, the global surgical package for CPT 28820 (amputation, toe: metatarsophalangeal joint) and CPT 28825 (amputation, toe: interphalangeal joint) includes all the necessary services normally furnished by a surgeon before, during and after a procedure.¹ Medicare payment for a surgical procedure includes the preoperative, intra-operative and postoperative services routinely performed by the surgeon. This payment also includes any services provided during this period by members of the surgeon’s group who are of the same specialty.¹ 

The codes CPT 28820 and 28825 have always had a postoperative global period of 90 days. However, on January 1, 2021, the postoperative global period for these procedures changed to zero days.² 

This represents a major change for most practices that traditionally submitted CPT 99024 (Postoperative follow-up visit, normally included in the surgical package, to indicate that an evaluation and management service was performed during a postoperative period for a reason(s) related to the original procedure) for postoperative visits for 90 days following the performance of CPT 28820 or CPT 28825.¹ Now practices should submit medically necessary postoperative visits with the appropriate level evaluation and management CPT code.²

There are advantages and disadvantages to this change. One advantage is the ability to submit payable CPT codes for providing medically necessary postoperative care. One disadvantage is patients who have financial responsibility for evaluation and management services in the form of cost sharing may experience a burden with copays and deductible payments for these visit types in a way that did not occur with previous submission of these visits with CPT 99024.

If you perform either or both of the procedures represented by CPT 28820 and 28825, be sure to make the necessary changes in your coding and documentation consistent with a zero-day global period that went into effect on January 1, 2021. 

Dr. Lehrman operates Lehrman Consulting, LLC, is a consultant to the APMA Health Policy and Practice Department, serves as an expert panelist on Codingline, and is a Certified Professional Coder. Follow him on Twitter @DrLehrman

Current Procedural Terminology (CPT^®) copyright 1966, 1970, 1973, 1977, 1981, 1983-2021 by the American Medical Association. All rights reserved. CPT is a registered trademark of the American Medical Association (AMA).  

References 

1. CMS Medical Learning Network. MLN Global Surgery Booklet. Available at: https://www.cms.gov/outreach-and-education/medicare-learning-network-mln/mlnproducts/downloads/globallsurgery-icn907166.pdf . Accessed January 4, 2021.  

2. Centers for Medicare and Medicaid Services. 2021 Medicare National Physician Fee Schedule Relative Value File. Available at: https://www.cms.gov/medicaremedicare-fee-service-paymentphysicianfeeschedpfs-relative-value-files/2021. Accessed January 4, 2021.