College Joins Fight Against Implementation of G2211 Code

The ACS, with 18 other surgical organizations, has expressed strong opposition to the implementation of Centers for Medicare & Medicaid Services (CMS) code G2211, which would penalize surgeons and negatively affect surgical patients.

In a letter sent last week to CMS, the 19 groups expressed continued opposition to the code and called for long-term payment reform. G2211 was first introduced in 2020 as an effort by CMS to pay more for certain office visits. These additional payments would predominately help primary care physicians even though most of the office visit codes for this type of care were increased in 2021. 

In the 3 years since G2211 was introduced, its flaws and the larger problems with the Medicare physician payment system have not been addressed.

“The ACS continues to advocate for a long-term, permanent fix to the broken payment system to enable better delivery of care for patients. 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,” said Patricia L. Turner, MD, MBA, FACS, ACS Executive Director and CEO.

Under G2211 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 unnecessary.

Additionally, G2211 would result in overpayments to those using it and 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 harmful to the healthcare system and not serve the long-term interest of patients.

Read the full letter from the 19 surgical organizations.