ACR® Highlights Negative Impact of G2211
The American College of Radiology® (ACR®) along with approximately 50 additional provider groups are pushing to terminate the implementation of Healthcare Common Procedure Coding System (HCPCS) code G2211, claiming implementation will penalize clinicians who do not use the code.
Evaluation and Management (E/M) add-on HCPCS code G2211 was finalized in 2021 by the Centers for Medicare and Medicaid Services (CMS) to account for the inherent complexity of care related to patients with serious or complex conditions. This took place despite the objections of the American Medical Association (AMA)/Specialty RVS Update Committee (RUC), the Medicare Payment Advisory Commission (MedPAC), as well as the provider community. As a result of these code changes, MPFS payments were estimated to increase by over $11 billion.
CMS delayed reimbursement of the code until January 1, 2024. Currently, the add-on code can be reported, but is a bundled code and is not separately reimbursed. CMS has proposed to change the status indicator of the code from “B” (bundled) to “A” (active), effective January 1, 2024, within the CY 2024 proposed Medicare Physician Fee Schedule (MPFS) rules.
CMS has estimated the code would be responsible for 90% of the overall budget neutrality reduction tied to the conversion factor (CF). It is in this conversion factor reduction where the ACR and coalition of provider groups cite the financial penalization for clinicians who cannot or do not report G2211.
Pressing both the Senate and House, the ACR-led advocacy wishes to permanently terminate the implementation of G2211, seeking short-term relief while continuing to push long term reform to MPFS as well.
