Podiatry Billing Denials: Global Periods & POS Code Errors
January 14, 2026

You performed a bunionectomy three weeks ago. The patient comes back for a routine post-op check. You bill an E/M code. The claim gets denied. You wonder what went wrong when you documented everything correctly.
This scenario happens in podiatry practices every single day. Medicare’s improper payment rate for podiatry hit 11.2% in 2024, with $216.9 million in projected improper payments. Two of the biggest culprits? Global period violations and place-of-service (POS) code errors.
Understanding global periods and POS codes is essential to protect your practice revenue and avoid audits that can tie up thousands of dollars in held payments.
Global periods are timeframes when all routine follow-up care is included in the original surgical payment. When you perform surgery with a global period, you can’t bill separately for related post-op visits.
Most podiatry surgeries fall into either the 10-day or 90-day category. Common procedures like bunionectomies, hammertoe corrections, and neuroma excisions typically have 90-day global periods. Simple procedures, such as nail avulsions, often have 10-day global effects.
The global surgical package includes:
What you CANNOT bill separately during the global period:
The denial reason usually says something like: “Service included in global surgical package” or “Payment adjustment, procedure performed during post-op period.”
| Situation | What Happens | Correct Action | Modifier Needed |
| Routine post-op visit | Included in the global, no separate payment | Don’t bill E/M or use CPT 99024 | None (or 99024 for tracking) |
| Unrelated E/M during global | Can be billed separately | Bill E/M with a different diagnosis | Modifier 24 |
| Complication requiring return to OR | Can be billed separately at a reduced rate | Bill procedure code | Modifier 78 |
| Unrelated surgery during global | Can be billed at full value | Bill’s new procedure | Modifier 79 |
| Related E/M on the same day as the procedure | Can be billed if significant | Bill E/M with procedure | Modifier 25 |
Success with global periods comes down to documentation and modifiers.
CPT 99024 is a reporting code for routine post-op care. It generates no payment but tells Medicare you saw the patient. CMS requires 99024 reporting to accurately track post-op visits.
Why report 99024? CMS uses this data to evaluate whether global packages should be redesigned. Missing 99024 reports can trigger audits and payment holds.
Use modifier 24 when you provide an E/M service during the global period for a problem completely unrelated to the surgery.
Example: Patient had a bunionectomy 2 weeks ago. Comes in today with an ankle sprain on the opposite foot. Bill the E/M with modifier 24 and link it to the ankle sprain diagnosis, NOT the bunionectomy diagnosis.
Critical documentation: Your notes must clearly state that it is “unrelated to recent surgery.” Specify the new problem’s location and cause. Don’t mention the surgical site unless you’re also addressing it.
Use modifier 78 when the patient needs to go back to the operating room during the global period for a complication of the original surgery.
The procedure is charged at a reduced rate (usually around 70-80% of the normal fee) because the global period has already been paid.
Example: Patient had hammertoe repair 30 days ago. Pin backs out and needs to be repositioned under anesthesia. Bill the pin repositioning code with modifier 78.
Use modifier 79 for a new, unrelated procedure performed during another surgery’s global period.
Example: Patient had bunionectomy 40 days ago (90-day global). Now needs nail avulsion on a different toe for an ingrown nail. Bill the nail avulsion with modifier 79.
This modifier tells the payer it’s a completely different problem and deserves a separate payment.
This modifier is for billing an E/M service on the same day as a procedure when the E/M was significant and separately identifiable.
Example: Patient comes in for routine nail debridement. During the visit, you also evaluate and manage their new diabetic ulcer, which requires detailed history, examination, and treatment planning beyond the nail care. Bill the E/M with modifier 25.
Warning: Don’t use modifier 25 to “force through” an E/M that’s really just the decision to perform the procedure. The E/M must be substantial and separately documented.
Place of service codes are two-digit codes that tell insurance companies WHERE you provided the service. Getting the POS code wrong causes immediate denials.
Each POS code has different reimbursement rates. Office-based services (POS 11) typically pay higher than facility-based services because they include overhead costs.
Medicare pays different amounts based on POS codes. The fee schedule has two rates:
Using the wrong POS code doesn’t just cause denials; it can also lead to other issues. It can result in incorrect payment that must be refunded later.
CMS enhanced auditing in 2025 to more closely monitor global period billing.
Build systems that catch these errors before claims go out.
Train your front desk, clinical staff, and billing team on:
Practices with quarterly internal audits saw 17% fewer denials than those with annual audits. Review:
Good documentation is your best defense against denials and audits.
When billing any service during a global period, your notes must include:
Every visit note should document:
This documentation supports your POS code selection if questioned later.
Managing global periods, POS codes, modifiers, and documentation requirements can overwhelm even experienced podiatry practices. Between seeing patients and running your practice, billing complexities can pull your focus away from patient care.
At West Virginia Medical Billing, we specialize in podiatry billing and understand the unique challenges you face with global periods and POS coding. Our expert team ensures every claim is submitted the first time.
Stop losing money to global period denials and POS code errors. Let our podiatry billing experts handle the complexity while you focus on treating patients. Contact us today for a free practice assessment
The claim will likely be denied as “service included in the global period.” Add modifier 24 with documentation to appeal or bill the first time.
Yes, if the complication requires a return to the OR (use modifier 78) or is a new problem needing significant E/M work (use modifier 24). Routine post-op issues, such as mild pain, are included in the global package.
Check the Medicare Physician Fee Schedule or your billing software for the CPT code’s global period. Major surgeries often have a 90-day waiting period, while minor procedures usually have a 10-day waiting period.
Always follow the payer’s specific POS rules, as commercial insurers may differ from Medicare. Call the insurer to confirm accepted codes before submitting claims.
Yes, CMS requires 99024 to track post-op care within global periods. Even though it pays nothing, proper reporting helps avoid audits and ensures complete documentation.