For decades, surgeons have lived with the global surgical package almost as if it were a law of nature. Perform the operation, and Medicare assumes a defined bundle of related post-operative care is included in the payment.
CMS is now openly questioning whether the assumptions inside that bundle still match reality.

In its proposed 2027 Physician Fee Schedule, CMS says it has accumulated several years of data indicating that some post-operative visits included in global surgical payments are not actually occurring even though payment for those visits remains embedded in the global package. CMS proposes pausing the MACRA-required global-surgery data collection while it determines how to improve the methodology. It is also seeking public comment on alternative data sources and future strategies for revaluing 10- and 90-day global surgical services.

That sentence should make surgeons sit up.

If CMS ultimately concludes that the typical number of post-operative visits embedded in a procedure is greater than the number actually being delivered, the logical endpoint could be revaluation of the global package. That does not mean CMS has proposed a specific across-the-board global surgery cut for 2027. It has not. But the agency is clearly gathering the evidence necessary to revisit how these services are valued.

The issue arrives after Medicare already broadened use of modifier 54 for 90-day global procedures when the operating surgeon expects to furnish only the surgical portion of the package. Medicare also recognizes modifiers 55 and 56 for post-operative and pre-operative portions in applicable transfer-of-care situations.

For orthopedic and spine surgeons, the stakes are substantial. A total joint replacement, fusion or other major procedure is not simply an intraoperative act. The professional fee reflects pre-operative judgment, surgical skill, risk and post-operative responsibility. If CMS begins separating what happens in the OR from what actually happens afterward, surgical reimbursement could become increasingly granular.

The comment deadline on the proposed PFS is September 14, 2026.

Surgeons have spent years complaining that policymakers do not understand surgery. When CMS asks for data about how surgery is actually practiced, that may be the worst possible time to remain silent.