Codes G2211 and GIDXX – Continued Uncertainty

If you have been listening to the discussions on Monitor Monday and Talk Ten Tuesday about the use of the new HCPCS code G2211, you know there remains some uncertainty on its use. Several weeks ago, the Centers for Medicare & Medicaid Services (CMS) stated that they would be releasing a FAQ document the next week. Well, that period came and went without a document.

To review, as defined, G2211 is an add-on code for use with the codes commonly considered office visit codes, 99202 to 99215, to recognize the “value” of longitudinal care of patients. As I discussed in the past, the code was really simply a way for CMS to get more revenue to primary care physicians who were seeing continuing payment cuts.

Well, the tricky part is that those same codes are also used in the hospital for outpatients and observation patients seen by consultants, assuming they are following the coding rules properly, which limit the use of hospital visit codes for outpatients to the physician who orders and provides observation services.

I finally had the opportunity to ask CMS about the code – specifically, if its use is limited to the office place of service. And the answer was no, the code can be used anywhere that the use of those visit codes is appropriate. That means the consultant seeing an observation patient or a hospitalist seeing a surgical patient in the hospital can also bill for G2211, if applicable.

Now, I will admit that hospitalists usually do not provide longitudinal care, as we normally think of it, over weeks or months or years, but CMS never really defines longitudinal care. Is two hospital visits considered longitudinal, meaning G2211 can be used? We really don’t know.

But when it comes to consultants seeing hospital patients, their care can be considered longitudinal, as many will have seen the patient in the office, or will see them there after the hospital stay. So a cardiologist who is asked to see their heart failure patient hospitalized for observation services can add G2211 to their visit billing.

And of course, one answer brings up another question: do doctors in the same practice count as one doctor, when considering longitudinal care? If the patient sees cardiologist Dr. Braun in the office and when hospitalized, Dr. Braun’s partner Dr. Wald is on call and sees them, can Dr. Wald use G2211? We all assume that with the same practice, the same specialty rules apply, but we really don’t know.

And another interesting point came up about this code. Picture the patient hospitalized as an outpatient with observation services for a recurrent urinary tract infection. The hospitalist starts antibiotics and consults infectious disease. The ID doctor sees the patient and discusses therapy options, and decides to see the patient in the office for ongoing care. That physician would bill for their evaluation and management visit with a code from 99202 to 99215 and the place of service of outpatient hospital. Because they are starting a longitudinal care relationship, they can bill G2211. But starting in 2025, if CMS finalizes the new code for ID doctors that I discussed last week, GIDXX, that doctor could also add that new code for the complexity of infectious disease treatment and monitoring and reporting.

But can they? Do infectious disease doctors get to double-dip and use two add-on codes? Once again, at this point, we don’t know. I have posed the question to CMS, and we will see if they address it in the 2025 Physician Fee Schedule Final Rule.

Let me add that all these add-on codes would be unnecessary if Congress would just change the way the physician fee schedule is calculated and stop cutting payment rates every single year.

It’s really a pretty simple concept.