• G2211 will not be paid until January 1, 2024. This provision was added to the stimulus package by Congress. CMS will have to comply. We have not yet seen the specific directives from CMS as the bill is not law. Once it becomes law, CMS will have a very short time to react. We are going to assume at this time; the code will become either bundled or non-covered. They could also rework the values to 0.00 and request or require reporting for tracking purposes.
The Initially projected cost to Medicare for G2211 was $3 Billion, approximately 3% of the Medicare budget for Part B. The change will require CMS to rework its budget neutrality projection and probably increase the conversion factor. At this point, we will project that it will not be necessary to report the G2211.
From a procedural standpoint, the MACs will have change processing programs to accommodate these last-minute changes, so plan for delays in payment for 2021 claims for a couple of weeks. The other changes affecting E/M codes, including the increase in value for E/M codes and the new guidelines, have not been affected by the law, so keep working on implementing those changes to be ready for January 1, 2020.
Other provisions of interest include:
• A payment raise of 3.75% across all specialties after budget neutrality adjustments with funds taken from the US Treasury General Fund.
This along with the budget neutrality impact of blocking payment for code G2211 could mean that the conversion factor for 2021 will be decreased by approximately 3.5% instead of 10.2%.
• Sequestration will be suspended until March 31, 2021, resulting in a 2% raise for the first quarter.
• A second round of the PPP program might be available to smaller practices that have proven impact from Covid and additional clarifications concerning first-round PPP money, taxes and expenses
• A new round of Provider Relief Funding will make money available to practices that prove that income and operations were affected by Covid.
We encourage all of you to read more about this legislation.
We will provide updates as they become available concerning both the Legislation and the CMS response to the legislation.
