Podiatry Coding & Billing Alert

The American Podiatric Medical Association (APMA) recently brought to our attention two clarifications relating to the article “Strengthen Your Understanding of the 2024 Physician Fee Schedule,” published in Podiatry Coding and Billing Alert Vol. 16, No. 1.

G2211: The Podiatry Coding and Billing Alert article cautioned podiatry practices to wait for clarification on which specialties would be able to report 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)). The APMA clarifies, however, that when the Centers for Medicare & Medicaid Services (CMS) originally created this code in 2021, they made it clear that G2211 was not specialty-specific.

APMA points to the CMS comment on page 284 of the 2021 Medicare Physician Fee Schedule (MPFS) final rule: “We did not restrict billing to any particular specialty or group of specialties.”

On page 279 of the same document, CMS also states it expects specialists to use G2211 when “care by specialists for a particular disease condition(s) is consistent and continuous over long periods of time.” The APMA points out that podiatric physicians often care for patients with complex conditions such as Charcot neuroarthropathy, osteomyelitis, and longstanding ulcers that pose the threat of lower-limb amputation.

Longitudinal care: The Podiatry Coding and Billing Alert article also mentions that podiatrists treat “foot problems that are not longitudinal in nature.” This is incorrect, per the APMA.

According to their letter to Podiatry Coding and Billing Alert, the APMA states “there are multiple examples of pathology podiatric physicians manage over extended periods of time, in many cases covering a decade or more of management, that require longitudinal care. Typical examples include Charcot neuroarthropathy, gait dysfunction, debilitating neuropathy, and chronic degenerative joint disease.”

We would like to thank the APMA for bringing these clarifications to our attention.