General Surgery Coding Alert

MPFS proposed rule slates implementation January 1.

Your general surgeons could see a pay boost for certain office and outpatient encounters next year.

Here’s why: Due to a separate add-on code for outpatient/office evaluation and management (E/M) services, certain Medicare providers may find themselves on the right side of a payment increase despite the proposed conversion factor (CF) decrease that you read about in “See How 2024 Proposed Rule Could Affect Your Practice,” General Surgery Coding Alert, Vol. 25, No 10.

Caveat: At this point, the new code implementation is recommended in the calendar year (CY) 2024 Medicare Physician Fee Schedule (MPFS) proposed rule, but that could change when the final rule comes out later this year.

Follow the +G2111 Saga

Beginning Jan. 1, 2024, the Centers for Medicare & Medicaid Services (CMS) proposes to implement the long-delayed HCPCS code +G2211 (Visit complexity inherent to evaluation and management associated with medical care services that serve as the continuing focal point for all needed health care services and/or with medical care services that are part of ongoing care related to a patient’s single, serious condition or a complex condition…), which you would append as an add-on code for outpatient/office E/M services.

The add-on code accounts for the “inherent costs” providers “incur when longitudinally treating a patient’s single, serious, or complex chronic condition,” oftentimes via outpatient/office E/M visits, a CMS rule fact sheet indicates.

Don’t miss: The agency insists that “establishing payment for this add-on code would have redistributive impacts for all other CY 2024 payments.” In plain language, that means specialties that use the code a lot may see a pay increase, but specialties that don’t will pay the price in decreased revenue due to the budget neutrality requirement.

Specifically: CMS estimates that more than 90 percent of the budget neutrality associated with the CF decrease for 2024 is due to the +G2211 add-on code.

Bottom line: For your specific surgery practice, the mix of services you typically provide will dictate how big of an impact +G2211 has on your revenue stream. While CMS doesn’t restrict the code’s use to certain specialties, those that are “office visit heavy” such as primary care providers are expected to see the largest boost from using the code. The downside is that providers who are less involved in patient encounters, such as pathology or radiology, will see downward pressure on reimbursement.

Reminder: “CMS originally finalized this policy in 2021, but Congress suspended its use and prohibited CMS from implementing it before 2024,” explains Atlanta-based attorney Doug Comin with law firm King & Spalding LLP in the firm’s Health Headlines newsletter. “Hence, CMS is proposing to implement the policy this year, but with refinements that would reduce the redistributive impact compared to the original proposal from 2021,” Comin continues.

Here’s How the Code Works

When a physician performs an E/M service involving ongoing care for a patient’s “single, serious condition or a complex condition,” the provider can report +G2211 in addition to the office/outpatient visit for new or established patients (99202-99215).

Telehealth: “CMS added +G2211 to the permanent telehealth list, so you may use the code even for an E/M carried out via telehealth,” says Terri Brame Joy, MBA, CPC, COC, CGSC, CPC-I, product manager, MRO, in Philadelphia.

The purpose of the code is to encourage holistic, patient-centered care that involves collaboration and coordination across specialties and provides continuity and consistency in patient care. CMS believes that the code represents the practice expense involved in that sort of care.