Surgeon Payments in the Crosshairs Following HHS OIG Audit

by  Ronald Hirsch, MD FACP CHCQM CHRI
Jul 9th, 2025

Today, in utilization news, there is a warning to any surgeons who may be reading this – or anyone who works with surgeons. You may see new efforts by the Centers for Medicare & Medicaid Services (CMS) to lower your fees in coming years. We have all heard about the fact that the Physician Fee Schedule has not kept up with inflation, and how angry physicians are about it, but there is a new threat on the horizon.

As background, surgeries have what is called a “global period.” The payment for the surgery to the surgeon covers that global period, which starts on the day of surgery and ends either that same day (as with a colonoscopy or simple laceration repair), after 10 days (as with an hemorrhoidectomy), or after 90 days (for major surgery). You can look up the global period for any CPT code here: https://www.cms.gov/medicare/physician-fee-schedule/search.

For each global period, CMS uses data from surgeons to determine the average time spent on each task on the day of surgery, including visiting the patient in pre-op, positioning the patient, scrubbing for surgery, performing the surgery, and then time spent post-operatively that day (and then the number of times that the patient is seen in the hospital, office, or other setting starting the day after surgery). And from that, they set the payment rate.

For example, we love to talk about total knee arthroplasty. So let’s take CPT code 27447 as an example. It has a 90-day global period. CMS estimated that 187 minutes are spent by the surgeon on the day of surgery, then they have three post-operative hospital visits and three post-operative office visits. Looking at a lesser surgery, incision and drainage of a simple abscess has a global period of 10 days, 41 minutes on the day of the procedure, then one follow-up office visit.

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This article originally published on July 9, 2025 by RACmonitor.

About Ronald Hirsch, MD FACP CHCQM CHRI

Ronald Hirsch, MD, is vice president of the Regulations and Education Group at R1 Physician Advisory Services. Dr. Hirsch’s career in medicine includes many clinical leadership roles at healthcare organizations ranging from acute-care hospitals and home health agencies to long-term care facilities and group medical practices. In addition to serving as a medical director of case management and medical necessity reviewer throughout his career, Dr. Hirsch has delivered numerous peer lectures on case management best practices and is a published author on the topic. He is a member of the Advisory Board of the American College of Physician Advisors, and the National Association of Healthcare Revenue Integrity, a member of the American Case Management Association, and a Fellow of the American College of Physicians. Dr. Hirsch is a member of the RACmonitor editorial board and is regular panelist on Monitor Mondays. The opinions expressed are those of the author and do not necessarily reflect the views, policies, or opinions of R1 RCM, Inc. or R1 Physician Advisory Services (R1 PAS).