Otolaryngology Coding Alert

Rest easy after seeing this new code indefinitely suspended.

With the long-anticipated COVID-19 relief bill finally being signed in to law, you’ll want to take a hard look at some of the various features of the bill that will impact your otolaryngology practice. In the formally titled Consolidated Appropriations Act (CCA), 2021, you’ll find a plethora of healthcare provisions that will undo much of what you just finished reading in the Medicare Physician Fee Schedule (MPFS) 2021 final rule.

Two of the most important changes include a revision to the budget neutrality cuts within the 2021 Medicare Physician Fee Schedule (MPFS) and a moratorium on payment for a brand new HCPCS Level II code.

Have a look at some of what’s included in the new relief bill — and what kind of impact it will have on your practice.

Take a Rain Check on Your G2211 Coding Worries

Before getting to the good news involving physician reimbursement, you should first take note that the CCA has placed a moratorium until 2024 on payment under the MPFS services that are part of ongoing care related to a patient’s single, serious condition or a complex condition. (Add-on code, list separately in addition to office/outpatient evaluation and management visit, new or established)).

Some within the coding community are sure to breathe cumulative a sigh of relief knowing that G2211 will no longer influence their evaluation and management (E/M) coding for the 2021 calendar year (CY). That’s because the details surrounding this code in the 2021 MPFS final rule were murky at best. However, others were looking forward to implementing G2211 into their practices since reporting the reporting of G2211 would allow for additional reimbursement for complex office and/or outpatient services.

Across nearly 12 pages within the final rule, CMS attempts to elaborate on the creation, use, and subsequent implementation of G2211. CMS prefaces by stating that they continue to believe “that the time, intensity, and physical effort (PE) involved in furnishing services to patients on an ongoing basis that result in a comprehensive, longitudinal, and continuous relationship with the patient and involves delivery of team-based care that is accessible, coordinated with other practitioners and providers, and integrated with the broader health care landscape, are not adequately described by the revised office/outpatient E/M visit code set.”

That’s where G2211 was supposed to come into play. The idea was that for applicable E/M services, you would include code G2211 alongside the respective new or established patient office/outpatient visit code. While CMS uses plenty of words to convey their point, the general consensus was the final rule didn’t have much clarity surrounding the use of G2211. Fortunately, CMS has at least three more years to come up with further instruction on G2211 reporting.

See Plan to Counteract MPFS Budget Neutrality Cuts

There’s more good news on the way for those practices that were bracing for a revenue hit following the Medicare payment reduction of 10.2 percent outlined in the MPFS 2021 final rule. As a means of providing relief to physicians during the public health emergency (PHE), the CCA includes the following:

“In order to support physicians and other professionals in adjusting to changes in payment for physicians’ services during 2021, the Secretary shall increase fee schedules under sub section (b) that establish payment amounts for such services furnished on or after January 1, 2021, and before January 1, 2022, by 3.75 percent.”

CMS explains that it’s not only the 3.75 percent pay raise increase that will be influencing reimbursement in 2021. The three-year suspension of code G2211 which, according to CMS, accounted for “about $3 billion — or 3 percent — of spending in the Medicare payment schedule,” helps to further reduce the planned budget neutrality decrease.

To consider: “Keep in mind that this is not a 3.75 percent increase over the 2020 conversion factor [CF],” says Barbara J. Cobuzzi, MBA, CPC, COC, CPC-P, CPC-I, CENTC, CPCO, of CRN Healthcare in Tinton Falls, New Jersey. “Rather, it’s a percent increase over the planned decrease of the CF of 10.2 percent as included in the 2021 MPFS Final Rule,” Cobuzzi explains.

While this is undoubtedly positive news, the underlying impact on otolaryngology practices is not as substantial as other specialties. Per the 2021 MPFS final rule, otolaryngology was expecting a combined 7 percent increase in reimbursement. Factoring in the combined impact without G2211 affecting the conversion factor (CF) and the additional 3.75 percent CF increase over the already 10.2 percent reduction, otolaryngology should now expect a net 8 percent combined impact for 2021. Audiology, previously anticipating a combined impact of -6 percent, should now expect a 0 percent combined impact in 2021. In fact, CMS now anticipates the majority of medical specialties will now see a neutral or positive change in reimbursement for 2021.

You can read the entirety of what’s included in the CCA at https://rules.house.gov/sites/democrats.rules.house.gov/files/BILLS-116HR133SA-RCP-116-68.pdf.