During the last few years, several publications have given rise to a fresh debate about co-management of surgical postoperative care. Legal, medical, and economic issues are involved. The government is concerned about possible abusive referral arrangements and violations of the federal anti-kickback statute. Ophthalmologists and optometrists are also concerned, given the prevalence of postoperative co-management of cataract surgery.

In 1998 and 1999, a few Medicare carriers published bulletins with specific coverage policies on postoperative co-management. These bulletins described limited circumstances that merit this approach and are, therefore, covered by Medicare. In those instances where physicians do not fall within the coverage guidelines, these carriers would not reimburse claims for postoperative co-management. More significantly, post payment review of paid claims that do not meet the carrier guidelines may be considered "false claims" subject to civil and/or criminal sanctions. This publication provides an overview of the various policies and forms required to bill for co-management.