Visit Complexity Add-On Code G2211 FAQs

Recently, we have been getting questions about the new Healthcare Common Procedural Coding System (“HCPCS”) code G2211 (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).

This code went into effect for The Centers for Medicare and Medicaid Services (“CMS”) on 1/1/2024.

As you can see from the description of the code, there is a lot to unpack here. In this article, we will address some of the questions we have received.

Question: Which providers can report code G2211?
Answer: This code may be billed by any provider who can bill the outpatient evaluation and management (“E/M”) codes 99202-99215, regardless of their specialty. This includes MDs, DOs, and NPPs, such as NPs and PAs.

Question: Can specialists use G2211 for consultations since Medicare does not pay for consult codes?
Answer: If the specialist is simply seeing the patient once to render an opinion, then G2211 would not be appropriate. If the specialist is going to manage a single serious or complex condition for the patient going forward, then you could report G2211 with your new patient office visit codes (99202-99205). When the patient returns to the office for you to manage that condition you could report established office visit code (99212-99215) with G2211.

Question: Since G2211 is an add-on code, what are the primary codes that must be reported with G2211?
Answer: You must report one of the codes ranging 99201-99215 with G2211. These are the only primary codes assigned to G2211.

Question: Can G2211 be billed for any place of service?
Answer: Only the following places of service codes are applicable for G2211: 02, 10, 11, 19, or 22.

Question: Can G2211 be billed as telehealth?
Answer: G2211 is on the 2024 telehealth list.

Question: Can I bill G2211 for audio only telehealth?
Answer: You cannot bill G2211 to Medicare for audio-only telehealth because the telephone visit codes (99441-99443) are not included in the primary codes that are required to bill G2211.

Question: What are the requirements that need to be documented to report code G2211?
Answer: Currently, there are no guidelines for documenting code G2211. We recently attended a MAC webinar where the speaker indicated that Medicare would be looking at the patient’s entire record to see evidence of a longitudinal relationship with the patient over time. Their medical record should demonstrate that the provider serves as the continuing focal point for all needed health or medical care services that are part of ongoing care related to a patient’s single, serious condition or a complex condition. We do not recommend providers use a templated statement to attempt to support G2211. Best practice would be to record the relationship with the patient in the documentation for each visit.

Question: How often can I report code G2211?
Answer: As of 2024, there are no frequency limitations on code G2211.

Question: Are there additional costs to the patient for code G2211?
Answer: Code G2211 is subject to Medicare cost sharing (coinsurance and deductible). See example below:

We estimate the cost to the patient for a moderate level office visit with G2211. Also, we recommend that you advise your patients in advance that you will be billing G2211, and that cost sharing applies.

Question: If I perform an in-office procedure with an E/M plus modifier 25, can I also report G2211?
Answer: There are edits in place that will deny G2211 when billed with an E/M code that has modifier 25 appended to it.

Keeping up with the nuances of HCPCS coding is exhausting. Pinnacle Enterprise Risk Consulting Services (“PERCS”) is here to help you navigate guidelines and remain compliant. If you have any questions or need assistance, please contact Alysia Delozier, CPC, CPMA, Sr. Physician Auditor and Educator at ADelozier@AskPHC.com, Angie Wood, CPC, Sr. Physician Auditor and Educator at AWood@AskPHC.com or Lori Carlin, CPC, COC, CPCO, CCS, CRC, Principal at LCarlin@AskPHC.com. They will be readily available to answer your questions and provide expert advice, so you are well equipped to move forward!

References:

https://www.cms.gov/files/document/r12461cp.pdf