Since July 1st, the Centers for Medicare and Medicaid Services (CMS) have been conducting audits of almost 300 different services to determine the proper usage of CPT code 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. This audit stems from concerns that the code, which is not directly associated to any payment, is not being used to report services that are part of a global surgery fee.

The origins of the audit lie as far back as 2012, in which the Office of Inspector General discovered that Medicare had reimbursed as much as $49 million for un-performed procedures that were covered under global fees. This discrepancy was far from uncommon; of the 300 surgeries that were analyzed, 211 had codes that did not match the number of services actually rendered. With such a drastic level of error, CMS agreed to conduct further research into the findings.

Since then, CMS has analyzed countless claims in order to find the most likely culprits. The result is a list of 293 common surgical procedures that typically have a 10-day or 90-day global period. Beginning last month, they began to audit practices of ten or more providers located in North Dakota, New Jersey, Rhode Island, Kentucky, Florida, Nevada, Oregon, Ohio, and Louisiana. These states were randomly selected to include an unbiased spread of data.

If your practice meets all three criteria (located in one of the nine affected states, containing ten or more providers, and performing surgeries whose codes are part of the investigation), then you are at risk for an audit. If you know that your workplace is going to be under scrutiny, be sure to review the proper usage of code 99024 so that your practice’s coders and providers alike are familiar with the necessary compliance.