CMS Releases New Guidance for Billing Office & Outpatient Visit Add-on Code G2211 | Heart Rhythm Society

CMS Releases New Guidance for Billing Office & Outpatient Visit Add-on Code G2211

On January 18th, CMS issued a new MLN Matters article titled, How to Use the Office & Outpatient Evaluation and Management Visit Complexity Add-on Code G2211, to provide guidance on billing the new code.

Regulatory Updates

CMS first proposed G2211 as part of its calendar year (CY) 2021 revisions to the New and Established Office and Outpatient (O/O) Evaluation and Management (E/M) code sets.  However, Congress issued a moratorium on Medicare payment of G2211 until CY 2024.

The finalized long descriptor for G2211 reads, "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 (Addon code, list separately in addition to office/outpatient evaluation and management visit, new or established)."  The MLN article reiterates CMS statements and vignettes issued in CY 2024 Medicare Physician Fee Schedule final rule.  The article also includes additional information on documentation rules for billing G2211:

Documentation Requirements
You must document the reason for billing the O/O E/M visit. The visits themselves would need to be medically reasonable and necessary for the practitioner to report G2211. In addition, the documentation would need to illustrate medical necessity of the O/O E/M visit. We haven't required additional documentation. Our medical reviewers may use the medical record documentation to confirm the medical necessity of the visit and accuracy of the documentation of the time you spent. These items could serve as supporting documentation for billing code G2211:

  • Information included in the medical record or in the claims history for a patient/practitioner combination, such as diagnoses
  • The practitioner's assessment and plan for the visit
  • Other service codes billed

EPs who treat patients for "ongoing care for a single, serious condition or a complex condition" (e.g., atrial fibrillation, heart failure, etc.) may wish to consider using this new code. CMS reminds practitioners and billers that usual patient co-payments and deductibles apply to G2211.  CMS also intends to release a Frequently Asked Questions (FAQs) document to provide additional clarification on billing for G2211.

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