Be Careful Billing the New CMS G2211 Add-on Code for Visit Complexity

CMS G2211 Add-on Code

Beginning January 1, 2024, CMS is finalizing the implementation of a separate add-on payment within the 2024 Medicare Physician Fee Schedule (PFS) for healthcare common procedure coding system (HCPCS) code G2211. This add-on code is intended to “better recognize the resource costs associated with evaluation and management visits for primary care and longitudinal care.” Physicians are allowed to list G2211 in addition to codes used in-office or outpatient visits for new or established patients (i.e., 99202-99215), and for telehealth visits. The idea behind the code is to help physicians receive payment for the extra time and effort expended when seeing more complicated patients.

Here’s the downside to implementing the new add-on code for visit complexity. Implementing payment for this add-on code has “redistributive impacts” for all other CY 2024 payments under the Medicare PFS, due to statutory budget neutrality requirements. In other words, to pay some (usually primary care) physicians more, someone else has to get paid LESS. The guidelines for when the code may be billed include prohibiting its use with modifier 25. Wound care practitioners spend a lot of time managing complex patients, but physicians should read this fact sheet carefully before deciding whether to bill this code.

Caroline Fife, MD

Dr. Fife is Co-Founder and Chief Medical Officer of Intellicure, Executive Director of the US Wound Registry, and Editor of Today’s Wound Clinic.

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