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Objective Analysis. Effective Solutions.

This report was initially published in 2019; this update was published in 2021 and includes clarification on RAND's definition of clean procedures.

In July 2019, as part of a contract with the Centers for Medicare & Medicaid Services (CMS), the RAND Corporation published three complementary reports related to post-operative visits bundled into Medicare payments for many procedures. The reports build on a new CMS requirement that some practitioners report on when bundled post-operative visits occur using a no-pay claim. CMS invited comments on these reports in the calendar year 2020 Physician Fee Schedule Proposed Rule. Although some organizations supported CMS's efforts to collect data on post-operative visits and the related RAND reports, others expressed concerns about CMS's claims-based data collection and the content of the reports. In this follow-up report, RAND researchers respond to those criticisms. The authors remain confident in their main conclusion that fewer post-operative visits were provided than expected, leading to Medicare overpayment for some procedures and underpayment for nonprocedure services, such as office visits. They recommend that CMS consider revaluing procedures with bundled post-operative visits in consideration of the newly available data on the number of post-operative visits actually provided to patients.

• Chapter One

  Background

• Chapter Two

  Summaries of the RAND Reports

• Chapter Three

  Claims-Based Report Comments and Response

• Chapter Four

  Survey Report Comments and Response

• Chapter Five

  Revaluation Report Comments and Response

• Chapter Six

  Conclusions

• Appendix A

  Organizations Providing Comments on the RAND Reports