Re: Global Codes Policies in the CY 2022 Medicare Physician Fee Schedule Proposed Rulee
Dear Administrator Brooks-LaSure:
On behalf of the undersigned 24 organizations, we write to voice our disappointment that the
Centers for Medicare & Medicaid Services (CMS) has failed to incorporate the American
Medical Association/Specialty Society Relative Value Scale Update Committee (RUC)-
recommended work and time incremental increases for the revised office/outpatient visit E/M
codes into the global codes. CMS has failed to address this issue in both the calendar year (CY)
2021 and CY 2022 Medicare physician fee schedule (PFS) rules. While CMS did finalize
adjustments for other bundled services, such as maternity codes, in the CY 2021 Medicare PFS
rule, organized medicine has been united in its recommendations that CMS incorporate the
incremental revised office/outpatient E/M values into all of the 10- and 90-day global surgical
package codes, as evidenced by the many comment letters and meetings over the past several
years. We request a meeting with CMS to discuss this issue in more detail.
Read full letter here
