Rules & regulations: Providers find confusion in CMS’ transfer-of-care modifier expansion

Why This Topic Matters

The proposal could affect how surgical and postoperative services are reported and paid, especially when care is split across clinicians or practices. Readers in coding, compliance, and practice administration will want to assess how the policy may change documentation expectations, claim reporting, and reimbursement processes.

Article Sections

1. Introduction to the CMS proposal

   Introduces the proposed expansion of transfer-of-care modifier use and the concerns it has prompted among coders and physicians.

2. Background on transfer-of-care modifiers

   Explains the general context for transfer-of-care reporting during the global surgical period and describes the current framework at a high level.

3. Result would be post-op ‘confusion’

   Summarizes concerns from a surgical advocacy perspective and a coding education perspective about how the proposal could affect workflow and claim reporting.

4. CMS seeks more accurate valuation

   Describes CMS’s stated rationale for the proposal, including its interest in global surgical package valuation, utilization patterns, and payment accuracy.