At Compass Healthcare Consulting, we closely monitor regulatory developments to help our clients stay ahead of compliance risks and issues that can impact revenue. A recent report from the U.S. Department of Health and Human Services Office of Inspector General (OIG) has placed a renewed spotlight on an often-overlooked code: 99024.
While this code carries a $0 reimbursement, the OIG’s findings make clear that how—or whether—your practice reports postoperative visits within global surgery packages is under scrutiny.
The OIG’s Findings: A Wake-Up Call for Surgical Practices
In a recent audit (Report A-05-20-00021 – View the PDF), the OIG evaluated whether physicians were accurately reporting postoperative visits furnished during global surgery periods. The results were troubling:
Widespread Underreporting: The OIG found that a significant percentage of postoperative visits were simply not reported at all. In one sample, hundreds of visits that were expected to have occurred during global periods were missing from claims data.
Impact of Underreporting: Because these visits went unreported with 99024, CMS lacked critical information about the frequency and nature of postoperative care associated with specific surgical codes. This lack of reporting may impact rate setting for surgical codes with a global period.
“Without complete reporting of postoperative visits, CMS does not have the data it needs to accurately value surgical services and ensure proper payment.”
— Adapted from OIG audit findings
Potential for Unbundling: The audit also identified instances where providers billed separate Evaluation and Management (E/M) services during global periods for routine follow-up care—a practice that constitutes unbundling and can trigger repayment demands.
Why This Matters for Your Practice
The OIG’s focus on 99024 is not an isolated event. It signals a continued federal interest in understanding the resources required for global surgery packages. Here’s what that means for you:
- Increased Audit Risk
If the OIG has identified underreporting as a national problem, Medicare Administrative Contractors (MACs) and other auditors are likely to follow suit with targeted probe audits. A pattern of zero 99024 reporting across your surgical cases can be a red flag that invites scrutiny.
- Unbundling Allegations
Routinely billing a standard E/M code (e.g., 99213) for a routine postoperative check—when the visit is related to the original procedure and falls within the global period—constitutes unbundling. This can lead to:
- Overpayment demands
- Penalties and interest
- Increased audit exposure
- The Future of Surgical Reimbursement
CMS uses data on postoperative visits to help determine the relative value units (RVUs) assigned to surgical codes. When the work of postoperative care goes unreported, surgical codes may become undervalued over time, affecting every provider in your specialty.
What Should You Report? A Refresher on 99024
The global surgical package has been developed to include a typical number of pre- and post-op services associated with each surgical encounter. CPT® Code 99024 for the postoperative follow-up visit, is normally included in the surgical package, to indicate that an evaluation and management service was performed during a postoperative period for a reason related to the original procedure. Think of 99024 as line item [proving that the visit occurred when the visit is already paid through the surgery’s global allowance.
CMS recently issued a reminder that reporting 99024 is required for practitioners in a group of 10 or more practitioners in 1 of these 9 states: Florida, Kentucky, Louisiana, Nevada, New Jersey, North Dakota, Ohio, Oregon, and Rhode Island. Your practice is exempt from required reporting if it has less than 10 practitioners but CMS encourages reporting for all practitioners. It is in your practice’s best interest to report 99024 when it applies so that the rates for surgical services are set to include an appropriate number of included postoperative visits.
Documentation Still Matters: Even though 99024 has no associated payment, the medical record must clearly document:
- The date of service
- The patient’s progress and findings
- The relation of the visit to the original procedure
Conversely, recognizing when an encounter is not routine and included in the postoperative care. In those cases, 99024 should not be used as a substitute. Instead, bill the appropriate E/M or procedure code with the correct modifier. CMS explicitly states that 99024 reporting does not change what is separately reportable; you should still bill separately payable services with their usual codes and modifiers
How Compass Healthcare Consulting Can Help
The OIG’s findings are a clear signal: postoperative visit reporting is under the microscope. Navigating this requirement requires more than just awareness—it demands action.
Our team of certified professionals—including CPMA (Certified Professional Medical Auditors), CPC (Certified Professional Coders), and specialty-specific coding experts—can help you:
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- Perform a Focused Audit: We’ll review your surgical coding and postoperative visit patterns to identify gaps, risks, and opportunities for improvement.
- Deliver Targeted Education: We provide customized training for your physicians and staff on global package rules, modifier usage, and 99024 requirements.
- Optimize Your Workflows: We’ll work with you to implement system changes that ensure accurate, consistent reporting.
- Prepare for Auditors: With a proactive assessment, you can address vulnerabilities before they trigger a government review.
Take the Next Step
Don’t wait for an audit notice to evaluate your postoperative visit reporting. The OIG has made its position clear: accurate data on surgical care is a federal priority. Connect with us today. Let our team of industry experts help you protect your practice’s compliance, revenue integrity, and peace of mind.
Disclaimer: The information provided herein is for general informational purposes only and does not constitute legal, coding, or compliance advice. Practices should consult with qualified professionals and refer to current CPT and CMS guidelines for specific situations. Compass Healthcare Consulting is not responsible for any errors or omissions or for any actions taken based on this information. CPT® is a registered trademark of the American Medical Association.
