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What the global period isWhy surgeon RTM is bundledWhen the surgeon's window opensNon-operative patientsThe PT/PM&R exceptionKeeping the team's timing straightKey takeaways
- During the 90-day global period, the operating surgeon generally can't bill RTM — it's bundled into the surgical package.
- The surgeon's RTM window opens after day 90.
- Non-operative patients have no global period — RTM is billable from the start of the episode.
- A PT or PM&R provider billing under their own entity is not bound by the surgeon's global period.
It's one of the most common RTM questions from orthopedic practices: the patient just had surgery, they're logging recovery data, the value is obvious — so why can't the surgeon bill RTM yet? The answer is the surgical global period, and the nuance that trips people up is who it applies to.
What the 90-day global period is
Major surgeries carry a 90-day global period — a window, starting around the procedure, in which Medicare considers routine related post-operative care to be already paid for as part of the surgical fee. The global package bundles the typical follow-up care a surgeon provides while the patient heals.
Why the surgeon's RTM gets bundled into it
Because RTM the operating surgeon performs during that window — monitoring the very recovery the surgery was meant to produce — reads as part of that routine post-operative care. So for the operating surgeon, RTM during the 90-day global period is generally not separately billable; it's considered included in the global package.
When the surgeon's RTM window opens
After the 90-day global period ends. Once the global closes, the operating surgeon can bill RTM for continued monitoring like any other eligible provider (subject to the usual RTM requirements). The clock is simply delayed, not cancelled.
Non-operative patients: billable from day one
No surgery, no surgical global period. For a non-operative (conservative-care) patient — say, an osteoarthritic knee or a rotator-cuff managed without surgery — there's no global window in the way, so monitoring can be billed from the start of the episode, once the other RTM gates are met (consent, enrollment, enough data-days, documented review time, and the interactive call for management codes).
The exception that pays: PT and PM&R bill independently
Here's the point most practices miss. The global period attaches to the operating surgeon's surgical fee. A physical therapist or PM&R provider billing under their own NPI / their own entity is a separate biller — and is not bound by the surgeon's global period. Each entity evaluates its own eligibility.
The patient can be in the surgeon's 90-day global period and still be monitored — and billed — by their PT.
So a post-operative patient whose surgeon can't yet bill RTM can often be enrolled and billed by the practice's PT in the same window. For a combined ortho + rehab practice, that's real, compliant revenue that's easy to leave on the table simply because the team assumed the global period blocked everyone.
Keeping the care team's timing straight
The practical move is to track, per patient: who's billing (surgeon vs PT/PM&R), the procedure date and the 90-day boundary, and whether the patient is operative or non-operative. Get those straight and the answer to "can we bill RTM yet?" is usually "yes — by the right provider."
BoneArc keeps the timing — and the documentation — straight.
Track the episode, the provider billing it, and the data-days, review time, and call attestation that make a month billable — so the right provider bills at the right time.
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