Evaluation and management (E/M) services make up a large share of the care provided by rheumatologists, primary care clinicians and other specialties. However, such services are underpriced in the Medicare Physician Fee Schedule (MPFS) because its structure has “passively devalued [E/M codes] over time,” according to the Medicare Payment Advisory Commission (MedPAC).
Effective treatment of complex disease requires a high level of expertise that rheumatologists develop through fellowship training and ongoing scholarship and which should be captured in coding and payment. To this end, the code G2211, which would be billed as an add-on to office/outpatient E/M visits, was finalized in the calendar year (CY) 2021 MPFS rule but was delayed until 2024 to finance conversion factor relief to all Part B clinicians during the COVID-19 pandemic. Because this moratorium ends on Jan. 1, 2024, the Centers for Medicare & Medicaid services (CMS) has appropriately included the G2211 code in the CY 2024 MPFS rule.
The ACR applauds the CMS for continuing to recognize the importance of the inherent complexity of services rheumatology professionals provide, and we ask Congress to support full implementation of G2211 as it will:
- Help ensure patients have timely access to care for complex, cognitive services;
- More accurately capture the resources and medical decision-making specialists provide; and
- Help sustain cognitive care physicians and address the cognitive specialty workforce shortage.
Unfortunately, by statute, all changes to the MPFS must be budget-neutral. This forces the CMS to reduce payments for some services as it increases payments for others. Congress should address these underlying issues that force the CMS to make cuts rather than disrupt the timely implementation of the G2211 code, which would make it harder for patients to access high-quality cognitive services. The ACR looks forward to continuing to work with Congress on broader changes to the Medicare reimbursement system.
