Primary Care Coding Alert

Question: How will the passage of the COVID-19 spending bill on Dec. 27, 2020 affect primary care billing and coding in 2021?

New York Subscriber         

Answer: The bill, known more formally as the Consolidated Appropriations Act, 2021 when it was signed into law on December 27, not only provided COVID-19 stimulus relief but also funded the federal government for the whole of fiscal year 2021. It contained both good and bad news for primary care.

First, the act “provides for a one-time, one-year increase in the Medicare physician fee schedule of 3.75 percent, to support physicians and other professionals in adjusting to changes in the Medicare physician fee schedule during 2021, and to provide relief during the COVID-19 public health emergency.” In other words, the bill revised the final rule to negate the 10.2 percent conversion factor cut and increase Medicare Part B payments by 3.75 percent, relative to what they would have been otherwise. So, while there will still be a cut in Medicare payments, it won’t be as big as the one finalized by the Centers for Medicare & Medicaid Services’ (CMS’) final rule.

However, to pay for the increase in part, the bill has placed a moratorium on payments for new 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)) until Jan. 1, 2024.

This is potentially bad news for primary care as CMS was “assuming that utilization [of the code] will be 90 percent of office/outpatient E/M [evaluation and management] visits” per the final rule, meaning an overall loss to primary care providers billing Medicare.

(To view the complete Consolidated Appropriations Act, 2021, go to rules.house.gov/sites/democrats.rules.house.gov/files/BILLS-116HR133SA-RCP-116-68.pdf).