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Our top priority is providing value to members. Your Member Services team is here to ensure you maximize your ACS member benefits, participate in College activities, and engage with your ACS colleagues. It's all here.

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Advocacy News

Nineteen Surgical Organizations Strongly Oppose CMS’ Plan to Implement the G2211 Code

Implementation of add-on code G2211 would inappropriately result in overpayments and at the same time penalize all physicians.

July 26, 2023

WASHINGTON, DC: The American College of Surgeons (ACS), with 18 other surgical organizations, has expressed strong opposition to the implementation of Centers for Medicare & Medicaid Services (CMS) code G2211, which would harm surgeons and, in turn, surgical patients.

In a letter today to CMS, the 19 groups expressed continued opposition to the code, which was first introduced in 2020 but has been delayed for three years. During this time, nothing has been done to fix flaws in the G2211 code or the larger problems with the Medicare physician payment system.

What Is Code G2211?

The G2211 add-on code is an effort by CMS to pay more for certain office visits. These additional payments would predominately help primary care physicians despite the fact that the majority of the office visit codes for this type of care were increased in 2021. 

There is no longer a valid justification for G2211. Under the new coding rules 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 redundant and, therefore, unnecessary.

Additionally, G2211 would inappropriately result in overpayments to those using it and at the same time 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.

Fixing Medicare Physician Payment

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 incredibly harmful to the healthcare system and not serve the long-term interest of patients.

“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.

Read the full letter from the 19 surgical organizations.

The 19 surgical organizations opposing the implementation of G2211 are:

American College of Surgeons

American Academy of Facial Plastic and Reconstructive Surgery

American Academy of Ophthalmology

American Association of Neurological Surgeons

American Association of Orthopaedic Surgeons

American College of Obstetricians and Gynecologists

American Orthopaedic Foot & Ankle Society

American Society of Metabolic and Bariatric Surgery

American Society for Surgery of the Hand Professional Organization

American Society of Breast Surgeons

American Society of Cataract and Refractive Surgery

American Society of Colon & Rectal Surgeons

American Society of Plastic Surgeons

American Society of Retina Specialists

American Urogynecologic Society

American Urological Association

Congress of Neurological Surgeons

Society for Vascular Surgery

The Society of Thoracic Surgeons

About the American College of Surgeons

The American College of Surgeons is a scientific and educational organization of surgeons that was founded in 1913 to raise the standards of surgical practice and improve the quality of care for all surgical patients. The College is dedicated to the ethical and competent practice of surgery. Its achievements have significantly influenced the course of scientific surgery in America and have established it as an important advocate for all surgical patients. The College has approximately 90,000 members and is the largest organization of surgeons in the world. "FACS" designates that a surgeon is a Fellow of the American College of Surgeons.

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