PYA Principal Martie Ross is featured in a recent issue of the Report on Medicare Compliance article, “CMS Sheds Light on G2211 Billing in New FAQs; ‘No Magic Language’ for Documentation.” 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, discusses the new FAQs provided by the Centers for Medicare & Medicaid Services (CMS) on the appropriate use of the new complexity add-on code, G2211, highlighting the lack of guidance regarding documentation requirements and other issues.
The G2211 add-on code was introduced in the 2024 Medicare Physician Fee Schedule Final Rule and relates to billing for ongoing care through a longitudinal relationship with a patient. “[The CMS guidance] specifically delineated when it is not appropriate to use the code,” Ross said. The test, she says, is whether the patient visit is one time or part of a current or prospective long-term patient relationship.
A challenge with documentation—which CMS has not fully addressed—is how to indicate a first visit is the start of a longitudinal relationship, Ross says.
The article also describes the use of G2211 in team-based care, CMS’s intention to adjust its policy on the use of modifier 25 with G2211, and the uncertainty of using G2211 with urgent care.
Read the full article about the use of the G2211 add-on code that ran on Sept. 9, 2024, on HCCA’s online platform, COSMOS, or access a PDF of the article.
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Ross was also featured in a related HCCA article about G2211 in April 2024.
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