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Medicare Administrative Contractor issues proposed co-management guidelines
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In September 2014, Novitas Solutions, a Medicare Administrative Contractor, issued a Proposed/Draft Local Coverage Determination for Co-management of Surgical Procedures (DL27481). The LCD specifically noted the following:
This policy addresses the indications and limitations of the co-management of surgical procedures that have a 10-day or 90-day global care period. It also provides guidelines for proper documentation. Management of the surgical procedures is the primary responsibility of the operating surgeon.
Alan E. Reider
The LCD acknowledges that there are situations in which a physician must transfer the care of the patient during the global care period. The LCD further notes that the physician receiving the patient must be licensed to manage all aspects of the postoperative care, including the ability to diagnose potential complications that would require another operation.
Co-management of surgical procedures has been a thorny issue for ophthalmology for many years. Previous attempts to impose severe restrictions on co-management by Medicare carriers were rejected by the Health Care Financing Administration (HCFA), the predecessor agency to CMS. The proposed LCD issued by Novitas, however, appears to avoid the more restrictive provisions that triggered HCFA’s previous intervention.
In particular, among the indications for co-management, Novitas includes a provision in which “the patient voluntarily wishes to be followed postoperatively by another physician.” In addition, under the heading “Limitations,” Novitas notes that the transfer of postoperative care is not covered if “the operating surgeon is available and he/she is able to manage other patients postoperatively, unless the patient voluntarily wishes to be followed postoperatively by another provider.” Thus, the Novitas LCD includes patient choice as a criterion to justify co-management. Patient choice was not included as part of the early carrier LCDs.
The LCD also provides, among other things, that the medical record must indicate that the patient was appropriately informed of the medical and/or logistic advisability of transfer of care along with any risks or benefits of this arrangement. The LCD also requires that the patient give written consent to this arrangement prior to its inception.
Finally, the LCD provides additional criteria that must be followed to assure compliance with co-management coverage requirements. Affected physicians should review the LCD in its entirety and be sure to comply with the applicable criteria. The proposed LCD identifies the relevant jurisdiction as Pennsylvania. Nevertheless, the LCD provides valuable guidance to all physicians who co-manage, and a similar policy may well be adopted by other Medicare Administrative Contractors in the future.