January 26, 2024
The Centers for Medicare & Medicaid Services (CMS) has issued an MLN Matters Article on the new G2211 code. AMDA realizes that there have been questions about this code. In our communications, we understand that CMS is also developing an FAQ document. We continue to work closely with other specialty societies through the American Medical Association’s RUC process that helped secure significant increases in work values for nursing facility codes. Currently, the G code is only billable in the office/outpatient setting. The reasoning for this determination was provided on the AMDA Forum:
“CMS felt that the RBRVS Update Committee’s (RUC) valuation of the Office/Outpatient service codes did not account for the additional office expense associated with patients with whom the physician has a longitudinal relationship. While this would apply mainly to primary care physicians, who manage patients with multiple complex problems, it could also be reported by specialists who manage patients with a single chronic condition. So, for instance, an Infectious Disease specialist could report G2211 with Office/Outpatient service codes for the ongoing longitudinal care of a patient with HIV. Based on its analysis, CMS did not find that the Nursing Facility services nor the Home/Residence services had the same issue with valuation. Thus, the final rule permitted the use of G2211 with only Office/Outpatient codes 99202-99215.”
The Society continues to engage with CMS in a dialogue around this and other codes. We state that much of the verbiage in G2211 notes that the relationship is with the provider and the staff. In the nursing facility setting, since physician practices do not pay the nursing home staff, CMS may have felt it inappropriate to reimburse for a relationship only with the physician and not staff.
The Society does not agree with CMS on this issue and is working to see if long-stay nursing facilities (POS 32) and assisted living/home care patients can be billable with this code. In those settings, there is indeed a longitudinal relationship with the patient and many of the functions described in G2211 are performed.
We will continue to provide additional information as it becomes available.
If you have questions and/or would like to discuss this, please email Alex Bardakh.
