ASA Opposes Cuts Related to Medicare E/M G2211 Payment Code

ASA has announced its opposition to the planned January 1, 2024 implementation of a Centers for Medicare and Medicaid Services (CMS)-created supplemental payment code for primary care services. The add-on code, G2211, will result in an extra Medicare payment on top of the payment for certain evaluation and management (E/M) codes.

CMS intends to implement the code in a budget neutral manner, which will result in offsetting cuts to Medicare payments for anesthesia, pain, critical care, and surgical services.

The implementation of G2211, which was previously delayed, was announced as part of the recently released Medicare Physician Fee Schedule proposed rule, the draft regulation setting Medicare payment rates for 2024. CMS explained that the code is intended to reflect ““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.”  The add-on may only be used in conjunction with office and outpatient E/M billing codes.

CMS has calculated that as much as 90% of the over 3% CMS proposed 2024 cuts to both the anesthesia and resource-based related value scale (RBRVS) conversion factors are the result of the budget neutral implementation of the add-on code.  

ASA has partnered with the American College of Surgeons and other key surgical stakeholders in urging CMS and Congress to again halt the implementation of G2211.