Ross HCCA G2211 key points
Published April 15, 2024

Ross Discusses G2211 in HCCA Article

PYA Principal Martie Ross is featured in the April 1, 2024, issue of the Report on Medicare Compliance article, “Key G2211 Definition is in ‘Eye of the Beholder,’ Complicating Compliance; FAQs are Coming.” The national publication is produced by the Health Care Compliance Association (HCCA) to provide updates on compliance strategies specifically pertaining to Medicare.

The article, written by Nina Youngstrom, describes the difficulty in clearly defining and applying the Centers for Medicare & Medicaid Services’ (CMS) new complexity add-on code (G2211), which was included in the 2024 Medicare Physician Fee Schedule final rule.

The article shares responses from CMS regarding the idea of a “longitudinal relationship” and how to code visits of new patients vs established patients and visits to a primary care physician vs a specialist.

“CMS believes it has created an objective standard, but all the permutations that providers raise clearly demonstrate it’s subjective. It’s in the eye of the beholder,” says Ross in the article. “Why this patient and not that patient? That’s the black hole,” she says.

Related to G2211 use for urgent-care visits, Ross states, “The longitudinal relationship is not transferable except for a substituted physician or incident-to services.” She also describes compliance ambiguities with specialists and calls for more clarity from CMS.

Read the full article about G2211 on HCCA’s online platform, COSMOS, or access a PDF of the article.

Learn more:

Check out the PYA on-demand webinar, Billing Medicare for G2211—What You Need to Know.

If you have questions about regulatory impacts or any other matter related to compliance or strategy and transactions, our executives are happy to help. Contact them by email or at (800) 270-9629.

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