Otolaryngology Coding Alert

Get the 411 on payment cuts, complex E/M code G2211, telehealth, and more.

Expect some give and take in the calendar year (CY) 2024 Medicare Physician Fee Schedule (MPFS) final rule, which the Centers for Medicare & Medicaid Services (CMS) published on Nov. 16 in the Federal Register. Actions everyone can get behind include advancing health equity and expanding access to comprehensive healthcare. But beware — physicians are facing greater pay cuts than originally anticipated.

The 1,230-page fee schedule is chock full of billing revisions and payment provisions and, per usual, there’s a lot to unpack. Let’s take a look at five policy changes that may affect your bottom line.

Beware, Conversion Factor Reductions Confirmed

Last July, CMS proposed a 3.34 percent cut to the conversion factor (CF). But in the final rule, the agency opted to reduce the CF further by a total of 3.37 percent, which equates to $32.7442 or $1.15 less than the 2023 CF of $33.89. On top of that, CMS anticipates overall payment rates under the CY 2024 MPFS will fall by 1.25 percent, according to the final rule.

Size Up Specialty Impacts

The final rule includes comparative data showing the estimated overall change to Medicare reimbursement, per specialty, expected for next year. Interestingly, despite the lower CF, some specialties, such as internal medicine and family practice, have a projected positive change in their Medicare payment percentage. Conversely, specialties such as allergy/ immunology and audiology are slated to realize a reduction of 1 and 2 percent, respectively. For some, like otolaryngology (0 percent), it’s a wash.

Add G2211 to Your Coding Arsenal in 2024

CMS has also made good on its promise to make HCPCS Level II add-on 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 ...) active beginning Jan. 1, 2024. However, while you’ll be able to report G2211, CMS will bundle the service and you won’t be reimbursed for it.

“It appears that G2211 will only be a tracking and reporting code in 2024, unfortunately. Keep in mind that if G2211 is not sufficiently reported over the coming year, there is a good chance that CMS may decide to never change the code into a reimbursable code, giving it a value to physicians who report it in future years. There is, therefore, incentive to report the code when caring for patients with serious or complex conditions in 2024 even though it will not be paid,” says Barbara J. Cobuzzi MBA, CPC, COC, CPC-P, CPC-I, CENTC, CPCO, CMCS, of CRN Healthcare Solutions of Tinton Falls, New Jersey.

Know Telehealth Flexibilities Can Continue

CMS plans to implement several telehealth-related provisions of the 2023 Consolidated Appropriations Act (CAA) through the end of next year. For example, CMS will:

• Continue the expanded scope of telehealth practitioners to include speech-language pathologists and qualified audiologists;
• Extend coverage and payment of certain telehealth services via an audio-only communications system;
• Continue to temporarily expand the scope of telehealth originating sites to include any site in the United States where the patient is located at the time of service; and
• Continue to define direct supervision to permit the immediate availability of the supervising practitioner through real-time audio and visual interactive telecommunications through Dec. 31, 2024.

The agency also plans to pay for telehealth services furnished in a patient’s home — place of service (POS) 10 (Telehealth provided in patient’s home) — at the higher, non-facility PFS rate beginning in CY 2024. Note that you will no longer use the POS that the physician normally provides the service in once the implementation of POS 10 takes effect on Jan. 1, 2024.

See Code Specifics for PNN Ablation, AOI Services

Posterior nasal nerve ablation: CMS finalized a work relative value unit (RVU) of 2.70 for both of the two new endoscopy codes for ablation of the posterior nasal nerve (PNN): 31242 (Nasal/sinus endoscopy, surgical; with destruction by radiofrequency ablation, posterior nasal nerve) and 31243 (Nasal/sinus endoscopy, surgical; with destruction by cryoablation, posterior nasal nerve). The agency is also moving forward with a work RVU of 3.91 for 30117; however, it reduced the value for 30118 from the proposed 9.55 to 7.75 RVUs.

“Keep in mind that the practice expense RVUs for the new codes 31242 and 31243 when performed in a non-facility (office) are significant to cover the costs of the disposable expenses incurred when performing the destruction of the PNN in the office,” Cobuzzi adds.