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Nineteen surgical organisations strongly oppose CMS' Plan to Implement the G2211 Code

Nineteen surgical organisations, including the American Society of Metabolic and Bariatric Surgery, has expressed strong opposition to the implementation of Centers for Medicare & Medicaid Services (CMS) code G2211, which would harm surgeons and, in turn, surgical patients.

In a letter to CMS, the 19 groups expressed continued opposition to the code, which was first introduced in 2020 but has been delayed for three years. During this time, nothing has been done to fix flaws in the G2211 code or the larger problems with the Medicare physician payment system.

The G2211 add-on code is an effort by CMS to pay more for certain office visits. These additional payments would predominately help primary care physicians despite the fact that the majority of the office visit codes for this type of care were increased in 2021.

According to the organisations, there is no longer a valid justification for G2211. Under the new coding rules for office visits, physicians and qualified healthcare professionals have the flexibility to bill a higher-level code to account for increased medical decision-making or total time of the encounter. The numerous codes currently available for documenting work and time across various levels of care make G2211 redundant and, therefore, unnecessary.


Additionally, G2211 would inappropriately result in overpayments to those using it and at the same time penalize all physicians due to a reduction in the Medicare conversion factor that will be required to maintain budget neutrality under the 2024 Medicare Physician Fee Schedule proposed rule.


In addition to the flawed G2211 code, Congress has not taken any steps to fix the broken Medicare physician payment system and create a long-term solution. A flawed G2211 code on top of a broken Medicare physician payment system would be incredibly harmful to the healthcare system and not serve the long-term interest of patients.


"The American College of Surgeons (ACS) continues to advocate for a long-term, permanent fix to the broken payment system to enable better delivery of care for patients,” said Dr Patricia L Turner, ACS Executive Director and CEO. “Congress can stop implementation of G2211, eliminate a majority of the expected 2024 Medicare physician payment cut, and not be required to expend any resources for this short-term solution."


Please click here to read the full letter from the 19 surgical organisations.


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