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Members are encouraged to reach out to CMS and Congress to express need for the code and to ensure they avoid any delay in its implementation

Sept. 8, 2023 (ACP) — In a major victory for internal medicine and primary care physicians, federal officials are poised to move forward with the implementation of a new code that will allow doctors to be more appropriately reimbursed for complex patient visits. The �������ý has launched a campaign to ensure the code withstands opposition and goes into effect as planned in 2024.

The Medicare-specific add-on code, known as G2211, is “designed to address the complexity inherent in office and outpatient evaluation and management (E/M) services,” said Dejaih Johnson, ACP governmental affairs and public policy senior associate. “Recognizing that some office and outpatient E/M visits are more complex and comprehensive than other E/M visits, the Centers for Medicare & Medicaid Services created this code to better recognize the inherent resource costs internal medicine and other clinicians incur when longitudinally managing a patient's overall health or treating a patient's single, serious or complex chronic condition.”

As Johnson explained, “G2211 reflects the time, intensity and practice expenses needed to meaningfully establish relationships with patients and address most of their health care needs with consistency and continuity.”

ACP and other medical societies have spent years advocating for this kind of code, which will allow internal medicine physicians and other clinicians to account for services like chronic disease management tracking, review of consultative or diagnostic reports, medication monitoring, safety outside of patient visits, and physician input at assisted living or nursing homes.

Physicians will be able to use the code in such situations as when they see long-term patients and when the complexity of a visit lies between level 4 E/M and level 5 E/M codes. “They can add this code for a visit to ensure that they're getting accurate payment for the work and the value of care they're providing,” Johnson said. “The code recognizes the inherent complexity of longitudinal care, which is critically important for primary care.”

ACP also believes the code will improve patient and population health outcomes and strengthen the Medicare program. According to Johnson, “it will help promote beneficiaries' timely access to primary care and other continuous services that promote better health care outcomes and help reduce spending; advance more appropriate payments for primary care and other longitudinal, continuous care under the Medicare Physician Fee Schedule; and help sustain primary care and other physician practices that Medicare beneficiaries rely on and bolster the physician workforce.”

CMS originally proposed the G2211 code for implementation in the 2021 Medicare Physician Fee Schedule, but opposition convinced Congress to delay it until 2024. This year, CMS included the code in its proposed 2024 Physician Fee Schedule, but there is pushback from critics who fear it will negatively affect other services in the fee schedule as the “budget neutrality” requirement mandates that added costs be balanced by reductions in other areas.

“The College understands there is concern about the impact of G2211's implementation given its utilization estimates and the impact to the conversion factor,” Johnson said. “ACP has prioritized budget neutrality reform for many years, and we understand the challenges. But the relief and opportunity provided by implementation of G2211 should not be delayed or halted as a result of a payment system that pits medical specialties against one another. We encourage the house of medicine to collectively support what are long overdue improvements to primary care and focus efforts on approaching Congress in support of systemic payment reform.”

ACP recently sent a letter to congressional representatives on this issue and continues to work with CMS. ACP is also calling on internal medicine physicians to urge CMS and Congress to support implementation of the new Medicare add-on code G2211 to support continuity and coordination of care.

“O�ܰ� allows individual members to send personalized letters to CMS and members of Congress expressing the need for the Medicare visit complexity code. These messages urge Congress to not take any action that would delay or halt implementation,” Johnson said. “ACP has also engaged with numerous interested parties, including our subspecialty societies as well as the American Academy of Family Physicians, to support and inform implementation.”

As for timing, “we look toward release of the final rule, which is around November, and we continue to serve as a resource for CMS and congressional representatives,” Johnson said. “As Congress returns for its fall legislative work period, we strongly urge representatives to not take any action that would delay or halt implementation of the G2211 code.”

Back to the September 8, 2023 issue of ACP Advocate