Podiatry Coding & Billing Alert

CMS makes good on its earlier proposals.

In July 2023, the Centers for Medicare & Medicaid Services’ (CMS) outlined key proposals for payment policies under the Medicare Physician Fee Schedule (MPFS) proposed rule for 2024. On Nov. 16, 2023, CMS confirmed those proposals, and the released final document now provides us with a more detailed understanding of what to expect in the upcoming year.

Continue reading to understand what 2024 has in store for you.

Expect no Change in Proposed CF

The bad news is CMS has finalized the conversion factor (CF) at 32.7442, a reduction of 1.1396, or -3.37 percent, compared to the 2023 CF of 33.8872.

But there’s some good news: the final rule still theorizes the impact of the CF decrease on the podiatric specialties to be the same as their estimates in the proposed rule. The finalized CF decrease will neither positively nor negatively impact podiatry practices, which CMS estimates will see a zero percent reduction in both nonfacility and facility payments.

Implement Split/Shared in 2024

The CY 2024 MPFS final rule also contains one of CMS’ most awaited rulings — its definition of split/shared visits and the additional decision to implement that definition beginning Jan. 1, 2024. Much to the relief of all that bill services to both Medicare and private payers, CMS has at last decided to finalize its definition to make the “substantive portion” of a split/shared visit “align … with the CPT^® [evaluation and management] E/M guidelines for this service.” The final rule added, “These guidelines should be applied to determine whether the physician or [nonphysician practitioner] NPP may bill for the service.”

Per CPT^®, this means “if code selection is based on total time on the date of the encounter, the service is reported by the professional who spent the majority of the face-to-face or non-face-to-face time performing the service.”

Applying the substantive portion guidelines to code selection based on MDM is a little trickier. Again, per CPT^®, “performance of a substantive part of the MDM requires that the “physician or other QHP [qualified healthcare professional] “has performed two of the three elements used in the selection of the code level based on MDM.” This is usually satisfied when the physician or QHP has “made or approved the management plan for the number and complexity of problems addressed at the encounter and takes responsibility for that plan with its inherent risk of complications and/or morbidity or mortality of patient management.”

If the physician or other QHP uses the amount and/or complexity of data element as one of the elements to determine the MDM level for the reported code level, however, CPT^® requires that “an independent interpretation of tests and discussion of management plan or test interpretation must be personally performed by the physician or other QHP.” Even so, “assessing an independent historian’s narrative and the ordering or review of tests or documents do not have to be personally performed by the physician or other QHP, because the relevant items would be considered in formulating the management plan,” per CPT^®.

So, it appears at this time, “if the physician is able to meet the level for the code selected with two of the three columns of MDM, the physician will bill the service under their provider number even if the QHP/NPP is also able to meet the MDM level for the code selected with two of the three columns of MDM. There will be scenarios where documentation may be unclear who performed which component of the MDM. So, documentation clarity will be of utmost importance when two providers are rendering and documenting the visit,” according to Lori Carlin, CPC, COC, CPCO, CRC, CCS, principal at Pinnacle Enterprise Risk Consulting Services.

According to Jennifer McNamara, CPC, CCS, CRC, CPMA, CDEO, COSC, CGSC, COPC, director of healthcare training and practice support at Healthcare Inspired LLC, in Bella Vista, Arkansas, “It is important to note that CMS only allows the split/shared benefit in a facility setting and it would not be covered in an outpatient office setting. It will be rare for a podiatrist to have a nonphysician practitioner share a hospital service to apply this benefit. If this does occur the documentation and medical necessity will need to be supported.”

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. (Add-on code, list separately in addition to office/outpatient evaluation and management visit, new or established) 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.

A note about G2211 and podiatry: According to Terry Fletcher, BS, CPC, CCC, CEMC, SCP-CA, ACS-CA, CCS-P, CCS, CMSCS, CMCS, CMC, QMGC, QMCRC, owner of Terry Fletcher Consulting Inc. and consultant, auditor, educator, author, and podcaster at Code Cast in Laguna Niguel, California: “Keep in mind that a podiatrist is a DPM and is limited to podiatric conditions and is treating foot problems that are not longitudinal in nature. Although it includes the concept of primary care and ‘other’ specialties in the final rule, we do not have enough information at this time. It would be best to wait until confirmation on what these specialties are from CMS.”

For further study: Find more information about using G2211 by going to www.cms.gov/files/document/physician-fee-schedule-pfs-payment-officeoutpatient-evaluation-and-management-em-visits-fact-sheet.pdf. Also, go to www.federalregister.gov/public-inspection/2023-24184/medicare-and-medicaid-programs-calendar-year-2024-payment-policies-under-the-physician-fee-schedule to download the CY 2024 MPFS final rule.