The CMS definition of surgery (found in the CMS State Operations Manual for Hospitals Interpretive Guidelines at §482.51) has led to various interpretations as to what types of procedures require a postoperative/post procedure note. The topic has been debated among AOs, with CMS, and other related parties. DNV GL offers the following clarification and plans to further address this clarification in future revisions of the NIAHO® Accreditation Requirements.

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